U.S. Customs and Border Protection is building CAPE — a new four-component system within ACE — to manage refunds of IEEPA tariffs. When live, it will allow importers and brokers to submit CSV-based refund claims, automate duty recalculations, schedule liquidations, and deliver refunds electronically to designated bank accounts.
What Is CAPE? An Overview
CAPE (Consolidated Administration and Processing of Entries) is a new refund processing system being built directly into CBP's existing ACE (Automated Commercial Environment) portal. It is the official mechanism by which importers and customs brokers will claim refunds for duties assessed under the International Emergency Economic Powers Act (IEEPA).
IEEPA duties — identified by HTS Chapter 99 classification numbers — were levied on a broad range of imports. CAPE creates a streamlined, automated path for those who paid IEEPA charges to recover those funds through the official CBP system.
The system is designed with four tightly integrated components that carry a refund request from initial submission through validation, duty recalculation, formal liquidation or reliquidation, and finally electronic payment. Each component hands off to the next automatically, minimizing manual intervention and refund timelines.
The Four Components of the CAPE Process
Understanding the complete process flow is critical to preparing your submissions correctly. A failure at any early stage removes entries from the refund queue entirely — making upfront accuracy essential.
1
Component One
CAPE Claim Portal
A new dedicated tab will appear in both importer and broker ACE Portal accounts. Filers upload a CSV file listing all entry summaries for which IEEPA refunds are being claimed. The portal then runs two sequential rounds of automated validation before a submission advances.
File Validations — The first pass checks for proper file formatting, completeness of required fields, correct filer identity, and overall file integrity. Any file that fails this check is rejected in its entirety with specific error codes, allowing filers to correct and resubmit the full file.
Entry Validations — Entries that clear file validation are then checked individually against ACE records. Each entry must (a) exist in ACE and (b) have at least one IEEPA HTS Chapter 99 number declared on it. Entries failing entry validation are removed from the submission individually. The remaining valid entries continue through the system.
2
Component Two
Mass Processing
Once a submission clears the Claim Portal, CAPE's Mass Processing engine takes over automatically. It performs two key actions on every validated entry summary: it removes all applicable IEEPA HTS Chapter 99 numbers from the entry, then recalculates duties as if the IEEPA charges had never been assessed.
This recalculation runs through ACE's standard duty calculation validations, ensuring that the revised duty figures comply with all existing system rules. Upon passing those validations, CAPE formally accepts the CAPE Declaration for each entry, locking in the recalculated duty amounts and advancing the entry to the next phase.
3
Component Three
Review and Liquidation / Reliquidation
After formal acceptance, entries enter the Review and Liquidation/Reliquidation phase. CAPE automatically schedules each entry to liquidate or reliquidate within a set number of days, creating a defined window during which CBP officers can conduct manual review if warranted. This phase also automatically calculates any applicable interest owed to the importer and updates each entry summary to reflect the corrected, final duty totals.
Processing schedule: Liquidations and reliquidations under CAPE are processed on Monday through Thursday each week. Entries scheduled to process on weekends or federal holidays will roll to the next available processing day.
4
Component Four
Electronic Refund Disbursement
When entries reach their scheduled liquidation or reliquidation date, ACE routes them through a CAPE-specific refund workflow. Refunds are consolidated by liquidation date and importer of record — or by a designated third party named on CBP Form 4811.
Once processed, funds are transmitted electronically directly to the designated bank account on file. There are no paper checks issued under this process. Accurate and current banking designations in ACE, including any Form 4811 designations, are therefore critical to timely receipt of refund payments.
Validation Requirements at a Glance
Both rounds of CAPE validation are fully automated and occur without human review. Understanding exactly what each round checks, and what causes failure, is essential for avoiding rejected submissions.
| Validation Round | What Is Checked | Failure Outcome |
|---|
| File Validation | File formatting, field completeness, filer identity, file integrity | Entire file rejected; error details provided; resubmission required |
| Entry Validation — Existence | Each entry number must exist in ACE | Individual entry removed; other entries in file continue |
| Entry Validation — IEEPA HTS | At least one HTS Chapter 99 IEEPA number must be declared on the entry | Individual entry removed; other entries in file continue |
| Duty Recalculation Validation | Revised duty amounts must pass ACE standard duty calculation rules | CAPE Declaration not accepted for that entry |
ACE Portal Access and Account Requirements
Because CAPE is built entirely within ACE, active and correctly configured ACE Portal access is a non-negotiable prerequisite. The CAPE Claim Portal tab will only appear for accounts that are properly registered and have appropriate filing permissions.
Key ACE requirements to verify before the portal goes live:
- Active ACE Portal account (importer or broker account, as applicable)
- Correct importer of record (IOR) assignments and account designations
- Up-to-date banking information for electronic refund receipt
- CBP Form 4811 on file if a third party will receive refund payments
- Verified access to all relevant entry summaries within your ACE account
Brokers should confirm that all importer account linkages are current. Any importer not yet active in ACE, or whose account designations are outdated, risks delayed or misdirected refunds even after a successful CAPE claim.
Background: What Are IEEPA Tariffs and Why Are Refunds Available?
The International Emergency Economic Powers Act grants the President authority to regulate international commerce in response to declared national emergencies. IEEPA tariffs, classified under HTS Chapter 99, were applied to a broad range of imported goods and represented additional duty charges on top of standard tariff rates. On February 20, 2026, these tariffs were deemd to be unlawful by the Supreme Court.
The CBP's creation of CAPE signals a formal, structured pathway for recovering IEEPA duties that were legitimately paid but are now eligible for refund. Unlike a protest (which challenges the legal basis of a duty assessment), the CAPE process is an administrative refund mechanism — meaning filers are not disputing a prior decision, but rather claiming a refund that CBP has authorized.
Entry eligible for CAPE refunds are those on which at least one HTS Chapter 99 IEEPA number was declared at the time of entry summary filing. The recalculated duty amount, after IEEPA charges are removed, becomes the basis for determining the refund owed, plus any applicable interest. Exclusions to the first phase of CAPE include entries subject to AD/CVD, entries where liquidation status is suspended/extended/under review, entries covering goods withrdrawn from bonded warehouses or foreign trade zones, and entries subject to drawback claims.
What to Do Now: Preparing Before CAPE Goes Live
The competitive advantage for importers and brokers will go to those who have done their homework before the portal opens. The submission process is largely automated, which means front-end preparation quality determines outcome quality. Contact us if you need assistance preparing.
📋 Pre-Launch Preparation Checklist
Audit paid IEEPA duties across all open and recently liquidated entries. Identify every entry on which an HTS Chapter 99 IEEPA number was declared and duties were paid.
Compile entry summary numbers for CSV submission. Organize your entry list in the format that will be required for upload. Clean, accurate data at this stage prevents file validation failures.
Confirm ACE Portal access is active and correctly configured for all relevant importer accounts. Verify that the correct importer of record designations are in place.
Review and update banking designations in ACE. CAPE refunds are sent electronically to the bank account on file. Outdated or missing banking information will delay payment.
Review CBP Form 4811 designations if a customs broker or other third party is intended to receive refund payments on behalf of the importer of record.
Monitor CBP and ACE communications for portal launch announcement. CAPE will become accessible via a new tab in ACE accounts; no separate registration is currently indicated.
Frequently Asked Questions
Is the CAPE portal live yet?
No. As of March 13, 2026, CAPE is under active development. CBP confirmed development progress across all four components on March 11, 2026, but has not announced a specific launch date. Organizations should prepare now so they are ready to submit at launch.
Who can use the CAPE Claim Portal?
Both importers and licensed customs brokers with active ACE Portal accounts will be able to access the CAPE Claim Portal tab. The specific filing permissions required are expected to mirror existing ACE entry summary access levels.
What entries qualify for a CAPE IEEPA refund?
Any entry summary that exists in ACE and on which at least one HTS Chapter 99 IEEPA classification number was declared at the time of filing is potentially eligible. The entry must pass both rounds of automated validation before it enters the refund pipeline. Exclusions to the first phase of CAPE include entries subject to AD/CVD, entries where liquidation status is suspended/extended/under review, entries covering goods withrdrawn from bonded warehouses or foreign trade zones, and entries subject to drawback claims.
How is the refund amount calculated?
CAPE's Mass Processing component removes all applicable IEEPA HTS Chapter 99 numbers from the entry and recalculates duties as though those charges were never assessed. The difference between the originally paid duties and the recalculated amount — plus any applicable interest — constitutes the refund.
How long does the process take from submission to payment?
CBP has not yet published specific timelines. After acceptance by Mass Processing, entries are automatically scheduled for liquidation or reliquidation within a set number of days (the specific window has not been publicly confirmed). Liquidations process Monday through Thursday, after which refunds are transmitted electronically.
Can a broker receive the refund on behalf of an importer?
Yes. Refunds can be directed to a designated party named on CBP Form 4811. You can add 4811 notify parties directly in the ACE portal. This form must be properly on file with the correct party information before the refund is processed, as CAPE disburses electronically to the designated account at the time of liquidation.
Do I need a separate ACE account to use CAPE?
No separate registration appears necessary. CAPE will appear as a new tab within existing ACE Portal accounts for users with appropriate access. Ensuring your current ACE account is active, complete, and correctly configured is the primary preparation step.
Key Terms
CAPE — Consolidated Administration and Processing of Entries
CBP's new four-component system within ACE for processing IEEPA tariff refund claims from submission through electronic payment.
ACE — Automated Commercial Environment
CBP's primary trade processing system and online portal used by importers, brokers, and carriers to file entries and manage trade compliance activities.
IEEPA — International Emergency Economic Powers Act
Federal statute granting Presidential authority to regulate commerce in declared national emergencies. IEEPA tariffs are classified under HTS Chapter 99.
HTS Chapter 99
The Harmonized Tariff Schedule chapter used to classify special-purpose tariff programs, including IEEPA duties. Presence of a Chapter 99 IEEPA number on an entry is required for CAPE eligibility.
CBP Form 4811
The CBP form used to designate a third party (such as a customs broker) to receive refund disbursements on behalf of the importer of record.
Reliquidation
The process by which CBP revises a previously liquidated entry to reflect corrected duty amounts — the mechanism by which CAPE refund amounts are formally established for eligible entries.
Entry Summary
The formal document (CBP Form 7501 or electronic equivalent) filed in ACE to declare imported merchandise, classify it under the HTS, and pay applicable duties. The entry summary number is the primary identifier used in CAPE CSV submissions.
