How does CAPE process IEEPA refunds?

Importers or their brokers upload a CSV file of affected entry summaries through the CAPE Claim Portal in ACE. The system validates the submission, removes IEEPA Chapter 99 HTS numbers, recalculates duties as if IEEPA tariffs were never declared, schedules liquidation/reliquidation with interest calculation, and issues refunds electronically via ACH or CBP Form 4811 designee.

What is the development status of CAPE?

As of March 11, 2026: Claim Portal is 70% complete (user interface done, validations under development), Mass Processing is 40% complete (focused on automated entry summary updates), Review and Liquidation/Reliquidation is 80% complete (liquidation function done, performance testing starting), and Refund is 60% complete (refund processing done, consolidation under performance testing).

Do I still need to file a protest if CAPE is coming?

Yes. The 180-day protest deadline under 19 U.S.C. § 1514 remains in effect regardless of CAPE availability. Do not rely on CAPE as a reason to delay filing a protest on liquidated entries approaching their deadline. CAPE is an additional processing mechanism, not a replacement for statutory protest rights.

What court case established the CAPE system requirement?

The CAPE system was detailed in a declaration filed in Atmus Filtration, Inc. v. United States (Court of International Trade, Court No. 26-01259). The CIT had previously ordered CBP to process IEEPA refunds following the Supreme Court's February 20, 2026 ruling in Learning Resources, Inc. v. Trump. The US Administration is expected to appeal the CIT order.

CBP CAPE System — IEEPA Duty Refund Processing via ACE

Q: Which entries are eligible for CAPE Phase 1?

Phase 1 will cover the majority of formal and informal entries on which IEEPA duties were paid. Excluded from Phase 1: unliquidated entries subject to antidumping or countervailing duties, entries with liquidation status 'Suspended,' 'Extended,' or 'Under Review,' warehouse withdrawals, and entries designated on a drawback claim.

Source: Declaration of Brandon Lord, Executive Director, Trade Programs Directorate, Office of Trade, U.S. Customs and Border Protection. Filed March 12, 2026 in Atmus Filtration, Inc. v. United States, Court of International Trade, Court No. 26-01259 (Document 39).

What Is CAPE?

CAPE stands for Consolidated Administration and Processing of Entries. It is a new capability being developed within CBP's Automated Commercial Environment (ACE) — the system of record for imported merchandise — to calculate and provide refunds of additional ad valorem duties imposed under IEEPA.

CAPE was developed in response to the Court of International Trade's March 4, 2026 order directing CBP to process refunds following the Supreme Court's February 20, 2026 ruling in Learning Resources, Inc. v. Trump that IEEPA does not authorize the President to impose tariffs.

CAPE's Four Components

CBP has designed CAPE with four integrated components that reflect how refund requests will proceed through the system:

1. Claim Portal

70% Complete

A web-based portal that serves as the entry point for IEEPA refund requests. A new tab will appear in both importer and broker ACE Portal accounts (not via ABI).

How It Works:

Upload a CSV file containing entry summary numbers for which IEEPA refunds are requested (a “CAPE Declaration”)
File validations: Checks that the request contains all required information, is properly formatted, and that the submitter is the IOR or the authorized broker that filed the entries. Rejects the entire submission if any file validation fails, with specific error details viewable in ACE.
Entry validations: Confirms each entry summary exists in ACE and has at least one IEEPA Chapter 99 HTS number. Removes failing entries individually but continues processing the rest.

Status: User interface complete. Automated validation programming under development.

2. Mass Processing

40% Complete

Automatically removes applicable IEEPA HTS numbers from validated entry summaries and recalculates duties.

Removes IEEPA Chapter 99 HTS numbers from each entry summary
Runs standard ACE duty calculation validations — the same process used for normal entry summaries
Calculates duties as if IEEPA duties had never been declared
Accepts the CAPE Declaration after successful processing

Status: Development focused on automated entry summary update process and related validations.

3. Review & Liquidation/Reliquidation

80% Complete

Initiates the liquidation/reliquidation process for entries in accepted CAPE Declarations.

Automatically sets entries to liquidate/reliquidate on a specified number of days from acceptance, allowing CBP manual review as needed
Updates underlying entry summaries to reflect new total duties paid
Automatically calculates interest
Processes liquidations/reliquidations Monday through Thursday each week

Status: Liquidation/reliquidation function complete. Performance testing beginning shortly. Additional development dependent on other CAPE components.

4. Refund

60% Complete

Directs processed entries to a CAPE-specific refund process within the ACE Collections refunds module.

Consolidates refunds by liquidation/reliquidation date and importer of record (or CBP Form 4811 designee)
Sends refunds electronically to the designated bank account

Status: CAPE-specific refund processing functionality complete within ACE Collections. Refund consolidation process under performance testing. Additional integration and testing planned in coming weeks.

Phase 1 Scope & Exclusions

CBP anticipates a phased development for CAPE. Phase 1 will cover the majority of formal and informal entries on which IEEPA duties were paid.

Excluded from Phase 1

Unliquidated entries subject to antidumping or countervailing duties (AD/CVD)
Entries with liquidation status Suspended Extended or Under Review
Warehouse withdrawals
Entries designated on a drawback claim
Certain other entry types (guidance to follow)

CBP will provide detailed guidance regarding the scope and functionality of each phase as it is implemented. CBP is also evaluating Paperwork Reduction Act compliance requirements.

What Importers Should Do Now

Identify all entries with IEEPA Chapter 99 HTS numbers — use the IEEPA.co calculator to determine which entries have IEEPA duty exposure and quantify the amounts
Compile entry summary data — CAPE will require CSV uploads with entry summary numbers. Prepare this data now so you are ready when the portal opens.
Confirm ACE Portal access — CAPE will be accessible through ACE importer and broker portal accounts. Ensure your access is current.
Verify electronic refund arrangements — refunds will be sent electronically to designated bank accounts or Form 4811 designees.
Do not wait for CAPE to file protests — the 180-day protest deadline under 19 U.S.C. § 1514 remains in effect. If your liquidated entries are approaching the deadline, file a formal protest regardless of CAPE status.

Critical: The CIT has paused the requirement for immediate refunds pending CAPE system readiness, and the US Administration is expected to appeal the CIT order. However, the statutory 180-day protest deadline is independent of CAPE and cannot be extended. Protect your rights by filing timely protests on liquidated entries while preparing for CAPE.

Legal Context

Feb 20, 2026Supreme Court rules 6–3 in Learning Resources, Inc. v. Trump that IEEPA does not authorize tariffs. All IEEPA duties vacated.

Feb 24, 2026CBP stops collecting IEEPA duties at 12:00 a.m. EST.

Mar 4, 2026Court of International Trade orders CBP to liquidate and reliquidate entries without IEEPA tariffs and process refunds.

Mar 6, 2026CIT orders CBP to report on implementation status.

Mar 12, 2026Brandon Lord, Executive Director of CBP Trade Programs, files declaration detailing the CAPE system. CIT subsequently pauses immediate refund requirement.

Frequently Asked Questions

What is CBP's CAPE system?

CAPE (Consolidated Administration and Processing of Entries) is a new platform within CBP's Automated Commercial Environment (ACE) designed to process bulk IEEPA tariff refund claims. It was detailed in a March 12, 2026 declaration by Brandon Lord, Executive Director of CBP Trade Programs, filed with the Court of International Trade in Atmus Filtration, Inc. v. United States (Court No. 26-01259).

How do I submit a CAPE refund request?

When operational, a new tab will appear in your ACE Portal account (both importer and broker accounts). You upload a CSV file listing the entry summary numbers for which you are requesting IEEPA refunds. The system validates your submission, processes the entries, and issues refunds electronically. Note: CAPE does not use the Automated Broker Interface (ABI).

When will CAPE be available?

As of March 11, 2026, CAPE components range from 40% to 80% complete. CBP plans a phased rollout beginning with straightforward claims. No specific launch date has been announced. The CIT has paused the immediate refund requirement pending system readiness.

Which entries are excluded from CAPE Phase 1?

Phase 1 excludes: unliquidated entries subject to antidumping or countervailing duties, entries with liquidation status “Suspended,” “Extended,” or “Under Review,” warehouse withdrawals, entries designated on a drawback claim, and certain other entry types. These will be addressed in subsequent phases.

Should I wait for CAPE before filing a protest?

No. The 180-day protest deadline under 19 U.S.C. § 1514 is a hard statutory deadline that cannot be extended. If your liquidated entries are approaching the deadline, file a formal protest immediately. CAPE is an additional processing path, not a replacement for statutory protest rights. You can pursue both paths simultaneously.

How will CAPE refunds be paid?

Refunds will be consolidated by liquidation/reliquidation date and importer of record (or a party designated via CBP Form 4811). Payment is sent electronically to the designated bank account. Ensure your electronic refund arrangements are current in ACE.

Prepare for CAPE: Know Your IEEPA Exposure

CAPE will require you to identify which entries have IEEPA Chapter 99 HTS numbers and the duty amounts involved. Use the IEEPA.co calculator to analyze your import data and quantify your IEEPA duty exposure before the portal opens.

Calculate Your IEEPA Exposure →

Licensing inquiries: ieepa@syntheticceo.com

CBP CAPE System: IEEPA Duty Refund Processing