U.S. Customs and Border Protection launches the CAPE administrative process on April 20, 2026, enabling importers to claim refunds for IEEPA-based tariffs ruled unlawful by the Supreme Court. With $170 billion at stake affecting over 300,000 importers, the process requires ACH registration and careful navigation of complex eligibility rules. Unresolved questions remain regarding finally liquidated entries and potential disputes between importers, customers, and suppliers over refund entitlements.
Benesch, Friedlander, Coplan & Aronoff LLP