(2026-04-17) Client Trade Update: CBP Implements New Process for IEEPA Duty Refunds

April 2026

U.S. Customs and Border Protection (CBP) has announced the rollout of a new refund mechanism for duties paid under the International Emergency Economic Powers Act (IEEPA). This new process, called Consolidated Administration and Processing of Entries (CAPE), is designed to simplify and accelerate how eligible importers receive refunds, including applicable interest.

What’s Changing?

Starting April 20, 2026, CBP will begin accepting IEEPA refund requests through CAPE within the ACE Secure Data Portal. Rather than processing refunds entry‑by‑entry, CAPE allows CBP to consolidate multiple eligible entries into a single refund request, streamlining review and payment.

Who Can File?

  • Importers of Record (IORs)

  • Authorized U.S. Customs brokers who filed entries on behalf of the importer

Only the importer or the broker who filed the original entry may submit a CAPE Declaration.

What Entries Are Eligible in Phase 1?

The initial phase of CAPE is limited to:

  • Certain unliquidated entries, and

  • Certain entries within 80 days of liquidation

CBP has indicated that additional entry types and scenarios will be added in future phases.  These include:

  • Entries that have been flagged for reconciliation, as well as Entry Type 09 – Reconciliation Summary;

  • Entries on a drawback claim;

  • Entries covered by an open protest;

  • Entries not filed in ACE, and entries without a liquidation status in ACE;

  • Entries subject to Antidumping/Countervailing Duties (AD/CVD), for which the
    Department of Commerce (DOC) has issued liquidation instructions, that are pending
    liquidation in accordance with 19 U.S.C. § 1504(d); and

  • Entries for which liquidation is final.

How to Request a Refund

Refund requests are submitted by filing a CAPE Declaration through the ACE Secure Data Portal:

  • Declarations are uploaded using a .CSV file (template available in ACE)

  • Each declaration may include up to 9,999 entries

  • No additional documentation is required beyond the list of entry numbers

  • CAPE Declarations are not filed through ABI

Once accepted, CBP will remove the applicable IEEPA Chapter 99 tariff and duties from the entry data and proceed with liquidation or reliquidation, as appropriate.

Refund Timing

  • We expect latency on April 20th and the following days due to the release of the new programming and the mass effort by Importers and Brokers to begin filing

  • CBP has expressed their timeline of approximately 45 days to review the claims

  • Refunds are expected within 60–90 days after CBP accepts a valid CAPE Declaration

  • Certain entries (e.g., extended, suspended, under review, or warehouse entries) will remain open and be refunded at liquidation

  • Refunds are issued by importer (or a designated refund recipient on CBP Form 4811)

Important Preparation Steps

To avoid delays, importers should ensure:

  • An active ACE Secure Data Portal account

  • ACH refund enrollment with current and accurate banking information

Without an ACE Portal or ACH enrollment, refund processing may be further delayed.

Our Support

If you need assistance determining eligibility, preparing CAPE Declarations, or reviewing your IEEPA exposure, our team is here to help guide you through this new process.

Contact your Client Relations Consultant for more information.

For technical CBP questions, CBP has provided the following contacts:

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