As of April 20, 2026, importers of record and authorized customs brokers can submit CAPE Declarations electronically through ACE for certain qualifying entries. Phase 1 is limited in scope and currently applies only to specific categories of entries while additional phases and procedures are still under development.
According to CBP's June 2026 Court of International Trade filing, Phase 1 currently covers approximately 63% of entries that included IEEPA tariffs. Phase 2 is set to launch on June 29, and Phase 3 is expected to begin in late July 2026.
What Is CAPE? An Overview
CAPE (Consolidated Administration and Processing of Entries) is a new ACE-based refund processing system developed by CBP to administer IEEPA duty refunds at scale. Rather than requiring refunds to be processed manually on an entry-by-entry basis, CAPE consolidates and automates much of the validation, recalculation, liquidation, and refund workflow.
The system allows importers and authorized brokers to submit refund requests electronically through a dedicated CAPE tab within the ACE Portal. Submitted entries are validated against ACE records, recalculated to remove applicable IEEPA duties, and then processed for liquidation or reliquidation before electronic refund disbursement. Refunds may include applicable statutory interest.
Current Scope of CAPE Phase 1
Phase 1 does not apply to all IEEPA entries. CBP has limited the initial rollout to specific categories of entries that can be processed within existing ACE functionality and liquidation timelines. Current Phase 1 eligibility generally includes:
- Certain unliquidated entries
- Certain entries liquidated within approximately 80 days prior to filing
- Certain entries with liquidation statuses of suspended, extended, or under review
- Certain warehouse entries and warehouse withdrawal entries
More complex entry types and finally liquidated entries outside current eligibility windows are expected to be addressed in future CAPE phases or through separate administrative or judicial processes.
Entries Currently Excluded From Phase 1
Based on current CBP guidance, CAPE Phase 1 does not currently process certain categories of entries, including some entries involving:
- Open protests
- Reconciliation entries
- Drawback claims
- Certain AD/CVD matters
- Entries outside current liquidation timing windows
Importers with excluded entries may need to preserve rights through protests or await future CAPE phases and additional CBP guidance.
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.
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.
Entries passing initial file validation may still fail secondary validation checks during later stages of CAPE review.
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.
CBP has clarified that ACH duty payment enrollment does not automatically establish ACH refund enrollment, and importers should verify that refund banking instructions are separately configured within ACE.
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 |
CBP reported in a May 26 Court of International Trade filing that nearly 50,000 CAPE refund initiation attempts were initially rejected during the system’s first month of operation. According to CBP, the most common file validation failures include:
- Importer of record or filer information that does not match the original ACE entry record
- Invalid or incorrectly formatted entry numbers
- Failure to follow the official ACE CSV template requirements
CBP also noted that submissions passing initial validation may still fail secondary validation if:
- The entry falls outside applicable reliquidation timing windows
- The entry lacks the required IEEPA HTSUS tariff designation
- The entry has already been included in a prior CAPE submission
In a May 26 filing with the U.S. Court of International Trade, CBP reported nearly 50,000 initial CAPE submission rejections during the program's first month. The most common causes included filer or importer-of-record mismatches, invalid entry numbers, and failure to use the prescribed ACE CSV format. CBP also reported that some submissions passing initial validation later failed secondary validation because the entry fell outside applicable reliquidation windows, lacked an IEEPA HTSUS number, or had already been submitted through CAPE.
ACE Portal Access and Account Requirements
To participate in CAPE, importers and brokers must have:
- Active ACE Portal account (importer or broker account, as applicable)
- Appropriate filer permissions
- Current importer-of-record relationships configured in ACE
- Electronic refund capability established through ACH
- Accurate banking information on file
- Any applicable CBP Form 4811 designations completed before refund processing
- Active ACH refund enrollment with CBP for electronic refund receipt
CBP has reported that thousands of otherwise payable CAPE refunds remain delayed because the importer or broker has not established a refund-enabled bank account configuration with CBP.
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.
Current Status of IEEPA Refund Processing
CAPE Phase 1 is now actively processing qualifying IEEPA refund claims through ACE. CBP has begun issuing reliquidations and electronic refund disbursements for accepted CAPE submissions, although processing timelines and sequencing continue to vary based on entry type and operational review requirements.
Some CAPE submissions may process in multiple batches, meaning certain entries may reliquidate or refund before others within the same submission.
In a May 26 filing with the U.S. Court of International Trade, CBP reported that accepted CAPE submissions through May 22 covered approximately 15.9 million entries containing IEEPA tariffs, and that approximately 54% of accepted entries had already liquidated or reliquidated without IEEPA duties. CBP further reported that approximately $60 billion in additional refunds had recently been forwarded to the Treasury Department for disbursement.
In a June 2026 Court of International Trade filing, CBP reported that accepted CAPE submissions through May 22 covered approximately 15.9 million entries containing IEEPA tariffs. CBP further reported that approximately 54% of accepted entries had already liquidated or reliquidated without IEEPA duties. CBP also reported forwarding approximately $60 billion in additional refunds to the Treasury Department for disbursement.
Importers should continue monitoring CBP Cargo Systems Messaging Service (CSMS) notices, ACE guidance, and applicable litigation developments, as eligibility rules and processing procedures may continue to evolve.
📋 Preparation Checklist
Frequently Asked Questions
Certain entry categories are not currently processed through Phase 1, including some entries involving: Open protests; Reconciliation filings; Drawback claims; Certain AD/CVD matters; Entries outside current liquidation timing windows CBP may address additional entry categories in future CAPE phases or supplemental guidance.
ACH duty payment enrollment alone may not enable refund receipt if ACH refund enrollment has not been separately established. CBP has indicated that some approved refunds remain pending solely because importers or brokers have not completed refund banking setup requirements.
- Importer of record or filer mismatches
- Invalid or improperly formatted entry numbers
- Failure to follow ACE CSV formatting requirements
- Entries falling outside current reliquidation timing windows
- Missing IEEPA HTSUS tariff designations
- Duplicate submissions for entries already included in a prior CAPE filing