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IEEPA Refunds – CAPE Module in ACE

IEEPA Refunds — CAPE Module in ACE

Latest Update – October 16, 2026

U.S. Customs and Border Protection (CBP) has now launched three phases of the Consolidated Administration and Processing of Entries (CAPE) system in ACE to facilitate refunds of duties collected under the International Emergency Economic Powers Act (IEEPA).

Most recently, CAPE Phase 3 launched on October 6, 2026, allowing certain importers with individual Court of International Trade (CIT) lawsuits and applicable court-ordered reliquidation to pursue refunds on finally liquidated entries.

On October 8, 2026, the CIT also certified a class action that could eventually provide an additional refund pathway for importers who did not file individual lawsuits. However, the decision has not automatically expanded CAPE eligibility, and CBP has not announced new refund procedures resulting from the ruling.

Importers should review their entry liquidation status, applicable CAPE phase requirements, and the latest CBP guidance before submitting refund declarations.

What Is CAPE? An Overview

CAPE (Consolidated Administration and Processing of Entries) is an ACE-based refund processing system developed by CBP to administer IEEPA duty refunds at scale. Rather than processing refunds manually on an entry-by-entry basis, CAPE automates much of the validation, recalculation, liquidation, and refund workflow.

The system allows importers and authorized brokers to submit refund requests electronically through the ACE Portal. Submitted entries are validated against ACE records, recalculated to remove applicable IEEPA duties, and processed for liquidation or reliquidation before electronic refund disbursement. Refunds may include applicable statutory interest.

CAPE has now launched in three phases, with eligibility determined by entry type, liquidation status, and applicable CBP requirements:

  • Phase 1 – Launched April 20, 2026: Covers certain unliquidated entries and entries within the applicable reliquidation window.
  • Phase 2 – Launched June 29, 2026: Expanded processing to certain reconciliation-related entries, subject to CBP eligibility requirements.
  • Phase 3 – Launched October 6, 2026: Covers certain finally liquidated entries for importers with individual Court of International Trade (CIT) lawsuits and applicable court-ordered reliquidation.

Important October 8 Update: The CIT certified a class action that could eventually provide an additional refund pathway for importers who did not file individual lawsuits. However, this decision has not automatically expanded CAPE eligibility, and CBP has not announced new refund procedures resulting from the ruling.

Not all IEEPA entries qualify for CAPE processing. Eligibility restrictions may apply to entries involving protests, reconciliation, drawback, antidumping or countervailing duties (AD/CVD), and certain liquidation statuses. Warehouse entry types 21 and 22 are also excluded under CBP's July 7 update.

Importers should review their entries against the requirements of the applicable CAPE phase and monitor CBP guidance for additional developments. Accurate entry information remains essential to avoiding validation errors and processing delays.

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.

Entries passing initial file validation may still face additional eligibility checks based on entry type, liquidation status, and applicable CAPE phase requirements. Successful validation does not guarantee final acceptance or refund payment.
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 proceed through CAPE's Review and Liquidation/Reliquidation process. ACE processes qualifying entries according to their liquidation status and applicable CAPE phase requirements. This includes certain finally liquidated entries covered by CIT-ordered reliquidation under Phase 3. CBP calculates any applicable statutory interest and updates the entry summary to reflect the corrected duty amounts.
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.

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

CAPE uses automated validation checks to review submitted files and individual entries against ACE records. These checks verify file formatting, entry information, applicable IEEPA tariff designations, and duty recalculations. Additional eligibility requirements may apply depending on the CAPE phase, entry type, and liquidation status. Entries that pass automated validation may still be subject to further CBP review before refund processing is completed..

Validation RoundWhat Is CheckedFailure Outcome
File ValidationFile formatting, field completeness, filer identity, file integrityEntire file rejected; error details provided; resubmission required
Entry Validation — ExistenceEach entry number must exist in ACEIndividual entry removed; other entries in file continue
Entry Validation — IEEPA HTSAt least one HTS Chapter 99 IEEPA number must be declared on the entryIndividual entry removed; other entries in file continue
Duty Recalculation ValidationRevised duty amounts must pass ACE standard duty calculation rulesCAPE Declaration not accepted for that entry

Current Status of IEEPA Refund Processing

Updated October 16, 2026

CBP has now implemented three phases of CAPE refund processing within ACE. Phase 1 covers certain unliquidated and recently liquidated entries, Phase 2 expanded eligibility to certain reconciliation-related entries, and Phase 3, launched October 6, allows certain finally liquidated entries covered by applicable Court of International Trade (CIT) reliquidation orders to be processed.

On October 8, 2026, the CIT certified a class action that could eventually provide an additional refund pathway for importers who did not file individual lawsuits. However, this decision has not automatically expanded CAPE eligibility or established new refund procedures.

CBP continues processing qualifying refund declarations, with timing dependent on validation results, liquidation or reliquidation requirements, and electronic refund setup. Importers should monitor CBP guidance and court developments for additional changes to eligibility and processing procedures.

📋 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 guidance and CIT litigation developments. Stay informed about changes to CAPE eligibility, Phase 3 processing requirements, and potential additional refund opportunities following the October 8 class-certification decision.
Review Phase 3 eligibility for finally liquidated entries. Determine whether the importer has an individual CIT lawsuit and an applicable court-ordered reliquidation. Importers without individual lawsuits should monitor further developments concerning the October 8 class action.

Frequently Asked Questions

Who can use the CAPE Claim Portal?
Importers of record and licensed customs brokers with active ACE Portal access and appropriate filing permissions may submit CAPE Declarations. Brokers must have proper account linkage and authorization for the importer accounts they are filing on behalf of.
What entries qualify for a CAPE IEEPA refund?
Eligibility depends on the applicable CAPE phase, entry type, liquidation status, and CBP validation requirements. Phase 1 covers certain unliquidated and recently liquidated entries, Phase 2 expanded processing to certain reconciliation-related entries, and Phase 3 covers certain finally liquidated entries subject to applicable CIT reliquidation orders. Not all entries on which IEEPA duties were paid automatically qualify.
How is the refund amount calculated?
CAPE removes applicable IEEPA HTS Chapter 99 tariff lines from eligible entries and recalculates duties as though the IEEPA duties had not been assessed. The difference between the originally paid duties and the recalculated duties becomes the refund amount. Eligible refunds may also include statutory interest.
How long does the process take from submission to payment?
Processing times vary depending on entry eligibility, validation results, liquidation or reliquidation requirements, and CBP review. Importers should not assume that every accepted declaration will result in a refund within a fixed number of days.
Can a broker receive the refund on behalf of an importer?
Yes. Refunds may be directed to an authorized third party through appropriate CBP refund designation procedures, including use of CBP Form 4811 where applicable. These designations should be completed and verified before refund processing begins.
Why aresome entries from my CAPE submission still pending?
CAPE submissions may process in multiple operational batches depending on validation status, liquidation timing, and CBP processing queues. Some entries within a submission may reliquidate or refund before others.
Why was my CAPE submission rejected?
CBP has identified several common rejection causes during CAPE Phase 1 implementation, including:
  • 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

Key Terms

CAPE — Consolidated Administration and Processing of Entries
CBP's 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 for special-purpose tariff provisions, including IEEPA duties. An applicable IEEPA Chapter 99 designation is necessary for CAPE processing but does not, by itself, establish refund 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 the liquidation of an entry to reflect corrected duty amounts, including when authorized or required by an applicable court order. Under CAPE Phase 3, certain finally liquidated entries may qualify for court-ordered reliquidation.
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.