On April 20, 2026 at 8:00 AM EST, US Customs and Border Protection launched the CAPE portal inside the ACE Secure Data Portal. CAPE stands for Consolidated Administration and Processing of Entries. It is the exclusive mechanism through which importers and customs brokers can now file IEEPA tariff refund claims for duties paid on goods imported between April 2025 and February 2026. The numbers are staggering: approximately USD 166 billion in IEEPA duties were collected from over 330,000 importers across 53 million shipments during that period. CBP has confirmed that approximately USD 127 billion of that, including statutory interest, is eligible for refund in Phase 1. If you are an Importer of Record who paid IEEPA duties on US imports during that period, your IEEPA tariff refund is waiting at CBP right now. This guide covers every step of the CAPE portal filing process, the exact eligibility rules for Phase 1, the mistakes already causing rejections, and what to do if your entries fall outside Phase 1 scope.
What the IEEPA Tariff Refund CAPE Portal Is and Why CBP Built It
On February 20, 2026, the US Supreme Court ruled in Learning Resources, Inc. v. Trump that IEEPA does not authorise the President to impose tariffs. CBP immediately stopped collecting IEEPA duties. The Court of International Trade subsequently issued orders in Atmus Filtration v. United States and Euro Nations Florida Inc. v. United States directing CBP to refund IEEPA duties already collected. The refund obligation applies not only to the original plaintiffs but to all importers who paid IEEPA duties on covered entries.
The scale of the refund obligation made entry-by-entry processing impossible. CBP designed CAPE as a batched, consolidated refund mechanism. Instead of filing a separate protest or correction for each of potentially thousands of entries, an importer uploads a single CSV file listing all eligible entry numbers. ACE processes the batch, removes the IEEPA HTS Chapter 99 codes, recalculates duties, and issues a consolidated refund payment. Full official CBP guidance is published on the CBP IEEPA Duty Refunds page, which is updated as new phases and guidance are released.
IEEPA Tariff Refund CAPE Portal Phase 1: Eligibility Rules
Phase 1 of the CAPE portal has specific eligibility criteria. Not every entry that paid IEEPA duties qualifies for Phase 1. Understanding the scope before filing saves time and prevents rejected declarations:
- Qualifying entries: Unliquidated entries on which IEEPA duties were paid, and entries that were liquidated within the preceding 80 days of the CAPE Declaration submission date. The 80-day window is a hard limit. Entries that liquidated more than 80 days before your filing date are not eligible for Phase 1
- IEEPA Chapter 99 requirement: Every entry included in the CAPE Declaration must contain at least one dutiable IEEPA Harmonized Tariff Schedule Chapter 99 code. If an entry has no IEEPA Chapter 99 code on the entry summary, ACE will reject it at entry-level validation
- Who can file: Only the Importer of Record named on the entry, or the licensed customs broker who filed the entry summary on the IOR’s behalf, can submit a CAPE Declaration. A third-party service provider, trade consultant, or accountant cannot file unless they are the licensed broker of record on the specific entries
- Interest included: CBP adds statutory interest automatically. The Q1 2026 overpayment interest rate is 7% per year for individual and non-corporate filers and 6% per year for corporate filers, compounded daily under 19 CFR 24.36 from the original duty payment date through the liquidation or reliquidation date
Entries Excluded From IEEPA Tariff Refund Phase 1
The following entry categories are excluded from Phase 1 and will be addressed in future CAPE phases or through Court of International Trade proceedings:
- Entries flagged for reconciliation and Entry Type 09 Reconciliation Summary entries
- Entries subject to Antidumping and Countervailing Duties where the Department of Commerce has issued liquidation instructions pending under 19 USC 1504(d)
- Entries subject to drawback claims (Type 47 Drawback entries)
- Entries that are extended, suspended, or under CBP review
- Warehouse entries (refunds will be issued at liquidation once these entries become eligible)
- Entries liquidated more than 80 days before the CAPE Declaration submission date
For entries outside Phase 1 scope, importers may need to wait for future CAPE phases or consider filing at the Court of International Trade. The applicable CIT limitations period is approximately two years from the date of liquidation.
Step-by-Step: How to File Your IEEPA Tariff Refund Through the CAPE Portal
Step 1: Confirm ACE Portal Access and Add the Importer Sub-Account
Log into the ACE Secure Data Portal at cbp.gov. You need an active ACE account with an Importer sub-account to access the CAPE tab. If you only have a Broker or Filer sub-account, add an Importer sub-account before proceeding. The CAPE tab is available within the Importer, Organizational Broker, and Filer sub-accounts. Without the correct sub-account type, the CAPE tab will not appear in your ACE interface.
Step 2: Set Up ACH Refund Banking Separately From Your Payment ACH
This is the single most common mistake in Phase 1 filings. The bank account you use to pay CBP import duties is not the account CBP uses to send you a refund. They are separate setups. You must add refund banking information specifically through the ACH Refund Authorisation tab within your Importer sub-account in ACE. CBP stopped issuing paper refund checks on February 6, 2026. All IEEPA refunds are paid electronically via ACH. If your ACH refund banking is not set up in ACE at the time your CAPE Declaration is accepted, CBP will hold your refund until the banking information is added. Refunds sit at CBP accumulating no additional interest during the hold period. Set this up before you file your first CAPE Declaration, not after.
Step 3: Compile Your Eligible Entry Numbers
Pull every entry number on which IEEPA duties were paid between April 2025 and February 2026. You can query these through your ACE Portal account using ACE Reports. For each entry, confirm that it contains at least one dutiable IEEPA HTS Chapter 99 code. Entries without a Chapter 99 IEEPA code will be rejected at entry-level validation. Do not include entries in the excluded categories: reconciliation entries, AD/CVD entries, drawback entries, extended or suspended entries, or entries liquidated more than 80 days before your filing date. Include only the entry numbers in your CSV file. CBP does not require any other information in the CSV. No commercial invoices, no supporting documents, no explanations. Entry numbers only.
Step 4: Prepare and Upload the CAPE Declaration CSV File
The CAPE Declaration is a comma-separated values (CSV) file using the CBP-provided template. Each CAPE Declaration is limited to 9,999 entries. If you have more than 9,999 eligible entries, submit multiple CAPE Declarations. Do not attempt to file through the Automated Broker Interface (ABI). ABI is not used for CAPE Declarations. CAPE must be filed through the CAPE tab in the ACE Portal web interface only. Do not attempt to initiate an IEEPA refund through a Post Summary Correction. CBP has explicitly prohibited PSC submissions for IEEPA refunds. PSC filings for IEEPA purposes will be rejected. Log into ACE, navigate to the CAPE tab, and upload your CSV file.
Step 5: Monitor the Two Validation Rounds
ACE runs two sequential validation rounds on every CAPE Declaration:
- File-level validation (Round 1): ACE checks that the submitter is the IOR named on the entries or the broker who filed them, that the CSV file contains a list of entry numbers, and that the file is correctly formatted. If Round 1 fails, ACE rejects the entire CAPE Declaration. You can download the Validation Result File from the File Upload Status column of the CAPE tab to identify the errors. Correct the issues and resubmit a new declaration. A failed Round 1 does not lock you out of refiling
- Entry-level validation (Round 2): ACE checks each individual entry number. For each entry, ACE confirms that the entry summary exists in ACE, that it contains at least one dutiable IEEPA Chapter 99 HTS code, and that the entry number does not appear as a duplicate in this or a prior declaration. If individual entries fail Round 2, only those specific entries are rejected. The remaining valid entries in the declaration continue processing. Download the entry-level results from the CAPE Claim Status section to see exactly which entries were rejected and why
Step 6: Track Refund Status and Receive Payment
Once a CAPE Declaration is validated and accepted, ACE removes the IEEPA HTS Chapter 99 codes from each valid entry and produces an updated version. CBP then reviews the entries and schedules them for liquidation or reliquidation. Unliquidated entries are scheduled for liquidation approximately 45 days from the acceptance date. Refunds are consolidated by IOR, or by the Form 4811 notify party if you have designated one, and paid by liquidation date. CBP anticipates refunds will be issued within 60 to 90 days of CAPE Declaration acceptance. The clock starts at acceptance, not at submission. Monitor your refund status through two ACE Reports:
- REV-603 Trade Refund report: Shows successful refunds issued to your account
- REV-613 ACH Rejected Refunds report: Flags any refund payments that bounced because banking information was missing or incorrect. Check this report after filing to catch and fix any ACH rejections before they delay your payment
Five Mistakes Already Costing Importers Their IEEPA Tariff Refund Through the CAPE Portal
Phase 1 has been live since April 20. CBP’s own communications describe the first 72 hours as including portal congestion, duplicate tax ID errors, and rejection cascades. Here are the five specific mistakes already causing rejections and delays:
- Filing without ACH refund banking set up: The most common cause of held refunds. CBP has the money but cannot pay it electronically. Every day without ACH information on file is a day your refund sits idle. Set up ACH in the Importer sub-account before submitting your first CAPE Declaration
- Including entries outside the 80-day window: Entries liquidated more than 80 days before your filing date fail entry-level validation. They are not rejected permanently, but they cannot be processed in Phase 1. Do not mix Phase 1 eligible and Phase 1 ineligible entries in the same declaration without checking liquidation dates first
- Attempting to file through PSC or ABI: Both routes are prohibited for IEEPA refunds. CBP explicitly states that Post Summary Corrections may not be used to initiate IEEPA refund claims. Brokers who attempt to file through ABI will find the submission rejected. CAPE tab in ACE Portal is the only route
- Including entries without Chapter 99 IEEPA codes: If an entry has no IEEPA Chapter 99 HTS code, ACE rejects it at Round 2. This catches importers who include entries where the goods were not actually subject to IEEPA duties, or where the entry was corrected and the Chapter 99 code removed. Validate every entry against your ACE records before including it in the CSV
- Filing a single declaration with more than 9,999 entries: ACE will reject a CAPE Declaration exceeding the 9,999 entry limit. Importers with large entry volumes must split their filing into multiple CAPE Declarations. This is straightforward but must be planned before filing to avoid the need to reformat and resubmit
What Happens After Phase 1: Future CAPE Phases and CIT Options
Phase 1 covers approximately 63% of entries that paid IEEPA duties based on CBP’s internal estimates. The remaining entries, those excluded by the Phase 1 categories above, will be addressed in subsequent CAPE phases. CBP has not announced specific dates for future phases. For importers with significant volumes of excluded entries, particularly reconciliation entries, AD/CVD entries, and entries liquidated more than 80 days ago, two paths are available:
- Wait for future CAPE phases: CBP has confirmed additional phases are planned. No timeline has been published. Importers with excluded entries should monitor CBP’s IEEPA Duty Refunds page for announcements
- Court of International Trade filing: Importers may file directly at the CIT to recover IEEPA duties on entries not covered by Phase 1. The applicable limitations period is approximately two years from the date of liquidation. Companies with large volumes of high-value excluded entries should assess CIT filing with their trade counsel
Why the IOR Is the Key to Every IEEPA Tariff Refund
The IEEPA tariff refund flows to the what an Importer of Record is and why it determines who receives the refund. Not to the buyer of the goods. Not to a downstream distributor who absorbed the duty cost through pricing. Not to a freight forwarder who facilitated the shipment. The IOR is the entity CBP recognises as responsible for duty payment and it is the entity CBP pays the refund to. If you purchased goods from a US distributor where the distributor was the IOR, you do not have a direct claim against CBP. Any sharing of the refund with you would depend on your contract terms or a separate commercial arrangement with the distributor. If you used a specialist Importer of Record service for your US imports during the IEEPA period, the refund flows to that IOR entity. Confirm with your IOR provider whether they have filed or are planning to file CAPE Declarations for the entries they managed on your behalf, and what their process is for passing the refund through to you.
How Carra Globe Supports Importers Through the IEEPA Tariff Refund CAPE Process
Carra Globe acted as Importer of Record for clients importing into the United States during the IEEPA duty period and is actively managing the IEEPA tariff refund CAPE portal process for those clients from April 2025 through February 2026. Our Global Trade Compliance team is compiling eligible entry lists, confirming Phase 1 eligibility against all entries managed on behalf of clients, and preparing CAPE Declarations for submission through our ACE Portal account for all qualifying entries. For clients who used their own IOR entity for US imports, our trade compliance team provides CAPE Declaration preparation support: entry eligibility review, CSV file preparation in the correct CBP format, pre-submission validation checking against Phase 1 criteria, and ACH refund setup guidance. For businesses new to the Importer of Record concept and why it determines who receives the IEEPA refund, our guide to importer of record vs customs broker explains the legal distinction in full. Our Delivered Duty Paid service incorporates Section 122 rates into all current US-bound landed cost calculations. For the full context of why IEEPA tariffs were struck down and how Section 122 replaced them, see our guides to the SCOTUS IEEPA ruling and our freight forwarding services for ongoing US import support and the Section 122 tariff 2026.
Frequently Asked Questions: IEEPA Tariff Refund CAPE Portal
How much is available in total IEEPA tariff refund claims?
CBP confirms approximately USD 166 billion in IEEPA duties were collected from over 330,000 importers across 53 million shipments between April 2025 and February 2026. Approximately USD 127 billion including statutory interest is eligible for refund in Phase 1. Individual refund amounts depend on how much your specific entries paid in IEEPA duties and the applicable interest rate: 7% annually for individual and non-corporate filers, 6% annually for corporate filers, compounded daily from the original duty payment date.
What is the 80-day IEEPA tariff refund window in CAPE Phase 1?
Phase 1 covers unliquidated entries and entries that were liquidated within 80 days of your CAPE Declaration submission date. If you file on May 1, 2026, you can include entries that liquidated on or after approximately February 10, 2026. Entries that liquidated before that date are outside the 80-day window and cannot be included in Phase 1. They may be eligible in future CAPE phases. The 80-day window is a rolling window based on your actual submission date, not a fixed calendar date. Filing earlier rather than later preserves access to more entries within the window.
Can my customs broker file my IEEPA tariff refund CAPE Declaration on my behalf?
Yes, provided the customs broker is the licensed broker who filed the original entry summaries on your behalf. The broker must file through their own ACE Portal account and can include up to 9,999 entries across multiple IOR accounts in a single CAPE Declaration. The broker cannot file for entries they did not originally file. A broker filing on your behalf should ensure Power of Attorney coverage is in place and that refund banking ACH information is set up correctly so the refund reaches the right entity.
How long will it take to receive my IEEPA tariff refund through CAPE?
CBP anticipates refunds will generally be issued within 60 to 90 days following acceptance of the CAPE Declaration. The clock starts at acceptance, not at the time of submission. For unliquidated entries, ACE schedules liquidation approximately 45 days from the acceptance date, with the refund following after CBP review. Entries with compliance concerns may take longer. Warehouse entries maintain their existing liquidation status and refunds are issued at liquidation. Monitor your REV-603 Trade Refund report in ACE for payment confirmation.
What if I paid IEEPA tariff duties through my supplier but was not the Importer of Record?
CBP pays the IEEPA tariff refund to the Importer of Record on the original entry, not to downstream buyers who absorbed the duty cost through pricing. If your supplier was the IOR and passed the duty cost to you through higher pricing, your refund claim is against your supplier under your contract terms, not directly against CBP. Some US companies are voluntarily sharing refunds with downstream buyers. Others are not. Check your supply agreement for duty-related provisions and engage your supplier directly about their CAPE filing plans and any refund sharing arrangement.
What happens to my IEEPA tariff refund for entries that do not qualify for Phase 1?
Entries excluded from Phase 1, including reconciliation entries, AD/CVD entries, drawback entries, extended or suspended entries, and entries liquidated more than 80 days before your filing date, will be addressed in future CAPE phases that CBP has committed to but not yet scheduled. For high-value excluded entries, filing directly at the Court of International Trade may be appropriate. The CIT limitations period is approximately two years from the date of liquidation. Consult a licensed customs attorney before pursuing CIT filing.