Yesterday, the Court of International Trade (CIT) and US Customs and Border Protection (CBP) met and provided an update on the plan to process IEEPA refunds.

Here’s the skinny:

CBP advised that they are developing a new refund system called the Consolidated Administration and Processing of Entries, or CAPE, within its existing Automated Commercial Environment (ACE) portal. CAPE is designed with four integrated components that will guide refund requests from initial submission all the way through to electronic payment. While CBP confirmed active development across all components as of March 11, 2026, to date, they estimate the overall development to be about 70% complete.

Here’s how it is supposed to work:

  • The process begins at the CAPE Claim Portal, a new tab that will appear in both importer and broker ACE Portal accounts.
  • To submit a refund request, filers upload a CSV file listing the entry summaries for which they are claiming IEEPA refunds.
  • ACE will then run two rounds of automated validation:
    • File Validations: Here, files will be checked for formatting, completeness, filer identity, and file integrity. Any submission that fails will be rejected with specific error details so that entry filers can correct and resubmit.
    • Entry Validations: This is where CBP confirms that each listed entry exists in ACE and has had at least one IEEPA HTS Chapter 99 number declared. Entries that fail are removed individually, while the remaining valid entries continue through the process.
  • Once a submission clears the Claim Portal, CAPE’s Mass Processing component takes over. It automatically removes all applicable IEEPA HTS numbers from the validated entry summaries and recalculates duties as if the IEEPA charges were never assessed. This step runs through ACE’s standard duty calculation validations before formally accepting the CAPE Declaration.
  • After acceptance, entries enter the Review and Liquidation/Reliquidation phase. CAPE automatically schedules entries to liquidate or reliquidate within a set number of days, giving CBP a window for manual review if needed. This component also automatically calculates any applicable interest owed and updates entry summaries to reflect the corrected duty totals. Liquidations and reliquidations are processed Monday through Thursday each week.
  • When entries reach their scheduled liquidation/reliquidation date, ACE routes them through a CAPE-specific refund process. Refunds are consolidated by liquidation date and importer of record (or a designated party named on CBP Form 4811). Once processed, funds are sent electronically, directly to the designated bank account.

What You Should Do Now

This project will be rolled out in phases.  Phase 1 is expected to include most entries with IEEPA duties.  Excluded from this phase will be unliquidated AD/CVD entries; warehouse withdrawals, drawback claims, and entries that have been suspended or are otherwise under review.  We have not yet received guidance on how or if protests will be managed in CAPE.

The portal isn’t live yet, but we do know that ACE registration/access will be critical to utilizing the CAPE tool.  Please also remember to ensure you are set up to receive your electronic refunds!

In our view, caution is still warranted. With a government appeal still possible, the portal unfinished, and so many questions still unanswered, importers should continue to take steps to protect their interests by controlling the parts of the refund process that remain within their control. These include considering filing a suit with the CIT and submitting protests.

We will be actively monitoring the situation and providing updates as they become available.