On April 10, 2026, U.S. Customs and Border Protection (CBP) announced that, beginning April 20, 2026, Phase 1 of the Consolidated Administration and Processing of Entries (CAPE) tool in the Automated Commercial Environment Secure Data Portal (ACE Portal) will begin accepting International Emergency Economic Powers Act (IEEPA) refund petitions, referred to as CAPE Declarations.
How CAPE Phase 1 is Expected to Work
CAPE is CBP’s response to successive orders by the U.S. Court of International Trade requiring CBP to create a process to process IEEPA tariff refunds.
According to affidavits filed by CBP in the court, CAPE is being designed to automate refunds of IEEPA duties. In general, according to CBP, once an importer submits a CAPE Declaration, CBP will remove the applicable Harmonized Tariff Schedule (HTS) codes indicating the applicability of IEEPA tariffs, and recalculate duties without IEEPA. It will then create an updated version of the entry. CBP will then review the updated entry and liquidate or reliquidate it. Refunds will be consolidated by Importer of Record (IOR) (or the party designated via CBP Form 4811) and by liquidation date.
Importers should anticipate that valid IEEPA refunds will generally be issued within 60-90 days following acceptance of a CAPE Declaration, unless a compliance concern requires further CBP review.
Key Limitation: Phase 1 Will Not Cover All Entries
CAPE Phase 1 will only cover certain unliquidated entries and certain entries within 80 days after liquidation.[1] As a result, many importers should expect that Phase 1 will not capture all refunds that are due.
Importers may want to identify entries potentially eligible for CAPE and start tracking liquidation status and dates now.
This will enable you to prioritize CAPE Declarations and preserve other remedies for entries that fall outside Phase 1 (e.g., protests for liquidated entries within the statutory window and entries subject to lawsuits in the Court of International Trade).
ACH Enrollment is Required to Receive Refunds
To receive refunds through CAPE, importers must enroll in CBP’s ACH refund program. As of February 6, 2026, CBP will only issue refunds electronically. In the ACE Portal Account, the account owner can submit the ACH Refund application under the ACH Refund Authorization tab to provide CBP with designated banking information as provided in this guide.
CBP has also stated that if it certifies a refund for issuance but cannot deliver the electronic refund solely because the importer (or designated third party) has not provided the required banking information, then no interest will accrue on that amount. For rejected refunds, the importer must complete the ACH refund application and then notify CBP’s Refunds Team at frn-achrefundsupport@cbp.dhs.gov to confirm completion and request reissuance to the designated bank account.
Monitoring Refunds
Importers will be able to monitor refunds through two reports available in ACE:
- The Rev-603 Trade Refund report can be used to track and manage an importer’s refund history with comprehensive detail. It will provide visibility into the status of each refund.
- The Rev-613 ACH Rejected Refunds report highlights any refunds that have rejected due to not being enrolled in ACH refunds.
Current Adoption of ACH Enrollment
As of April 9, 2026, CBP reported that 56,497 importers had enrolled in its automatic refund system, accounting for 82% of entries for which IEEPA duty payments and/or duty deposits were paid. Given the shift to electronic refunds—and CAPE’s reliance on ACH—timely ACH enrollment remains critical for importers seeking prompt refunds. Importers that have not enrolled should consider doing so promptly to avoid rejected refunds and potential loss of interest.
Footnotes
[1] Additional coverage includes: Entries with liquidation status suspended, extended, or under review (refund issued after liquidation); Entries subject to AD/CVD if liquidation is suspended pending instructions from the Department of Commerce (refund issued when CBP receives instructions from DOC to lift the suspension and liquidate the entries); and Warehouse and withdrawal entries (refund issued after liquidation)
