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ARTICLE · 24 APRIL 2026

IEEPA Update: Phase I Refunds Available Now

U.S. Customs and Border Protection has launched Phase I of its CAPE system in ACE to process IEEPA tariff duty refunds following the Atmus Filtration court order.

United StatesCorporate/Commercial Law
As part of its response to the Court of International Trade’s (CIT) order to refund and reliquidate tariff duties paid under the International Emergency Economic Powers Act (IEEPA) in Atmus Filtration, Inc. v. United States, the U.S. Customs and Border Protection (CBP) committed to creating a Consolidated Administration and Processing of Entries (CAPE) functionality within the Automated Commercial Environment (ACE). The CAPE system is now operational for Phase I of its refund process as of April 20, 2026, at 8 a.m. EDT.

How to File a CAPE Declaration

CBP has made clear that the refund process will occur in phases. For now, CBP has only defined Phase I. As of April 20, 2026, at 8 a.m. EDT, CBP is accepting IEEPA refund requests (CAPE Declarations) for certain entries within two categories: (1) unliquidated entries and (2) entries liquidated within the preceding 80 days. A CAPE Declaration is uploaded to the ACE Portal, checked for accuracy, and submitted to a batch run to validate

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