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ARTICLE · 10 APRIL 2026

Refund Rollout: Getting Your House In Order

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U.S. Customs and Border Protection has launched Phase 1 of its CAPE tool to process IEEPA tariff refund petitions, creating an automated system for importers to reclaim duties paid under International Emergency Economic Powers Act orders. The new system requires ACH enrollment and covers only certain unliquidated entries and recently liquidated entries, leaving many importers to pursue alternative remedies for entries falling outside Phase 1 parameters.

United StatesInternational Law
Jonathan Wang
Jonathan Wang
J. Scott Maberry
J. Scott Maberry
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On April 10, 2026, U.S. Customs and Border Protection (CBP) announced that, beginning April 20, 2026, Phase 1 of the Consolidated Administration and Processing of Entries (CAPE) tool in the Automated Commercial Environment Secure Data Portal (ACE Portal) will begin accepting International Emergency Economic Powers Act (IEEPA) refund petitions, referred to as CAPE Declarations.

How CAPE Phase 1 is Expected to Work

CAPE is CBP’s response to successive orders by the U.S. Court of International Trade requiring CBP to create a process to process IEEPA tariff refunds.

According to affidavits filed by CBP in the court, CAPE is being designed to automate refunds of IEEPA duties. In general, according to CBP, once an importer submits a CAPE Declaration, CBP will remove the applicable Harmonized Tariff Schedule (HTS) codes indicating the applicability of IEEPA tariffs, and recalculate duties without IEEPA. It will then create an updated version of the entry. CBP will then review the updated

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