CAPE Launches April 20: What CBP's New IEEPA Refund Process Actually Does

Sort your entries first

Every IEEPA-era entry falls into one of four buckets. Sorting them is the most useful thing an importer can do before April 20.

1. Phase 1 ready. Unliquidated entries and entries within 80 days of liquidation, with no drawback designation, no reconciliation flag, no open protest, and no AD/CVD liquidation instructions from Commerce. File these on April 20. They are what Phase 1 was built for.
2. Accepted, refund deferred. Entries with a liquidation status of Suspended, Extended, or Under Review, and AD/CVD entries still under Commerce suspension, are accepted into CAPE. CBP will strip the IEEPA Chapter 99 lines and update the entry version, but the refund will not pay out until the entry liquidates in the normal course. Still file the Declaration. Just do not expect the refund on the Phase 1 timeline.
3. Protest track. Liquidated entries approaching the 180-day protest window under 19 U.S.C. §1514. Once that window closes without a protest on file, the liquidation is final and conclusive, and there is no clean administrative path back. CAPE does not reopen that door.
4. Later phase. Drawback-designated entries, Entry Types 08 (Duty Deferral), 09 (Reconciliation Summary), 23 (TIB), and 47 (Drawback), entries flagged for reconciliation, AD/CVD entries with Commerce liquidation instructions, entries finally liquidated past 180 days, and entries not filed in ACE. CBP has said later phases will address these. No scope or timeline has been published.

If you have a few hundred IEEPA-era entries, a spreadsheet works. If you have thousands or tens of thousands, it does not. That is the real constraint on April 20.

What CAPE is

CAPE stands for Consolidated Administration and Processing of Entries. CBP introduced it in CSMS #68315804 on April 10, 2026, then followed up with an operational update in CSMS #68340863 on April 13, 2026, one week before the portal opens. It lives inside the ACE Secure Data Portal, the web interface importers and brokers already use for account management, reports, and statements. Day-to-day entry filings still flow through ABI. CAPE is a separate workflow bolted onto the Portal.

The April 13 update confirms the core mechanics. Filers access the CAPE Tab through their ACE Portal account, upload a CSV containing up to 9,999 entry numbers per Declaration, and nothing else. As CBP put it, "Only the entry numbers should be included in the CSV file – no other entry-related information is needed." Only the Importer of Record, or the authorized broker who filed the original entry summary on that IOR's behalf, may submit. For eligible unliquidated entries, CBP says "importers and authorized brokers may anticipate that valid IEEPA refunds will generally be issued within 60 to 90 days following acceptance." Refunds consolidate by IOR or designated 4811 party and liquidation date, and disperse electronically via ACH under Executive Order 14247.

The mechanism is a CAPE Declaration. An Importer of Record, or the authorized broker who originally filed on that IOR's behalf, uploads a CSV listing entry numbers eligible for an IEEPA refund. CBP validates the file, removes the Chapter 99 IEEPA lines from each accepted entry, recalculates duties as if the IEEPA tariffs had never been declared, liquidates or reliquidates the updated entry, and issues a consolidated ACH refund grouped by IOR and liquidation date.

Section 301, Section 232, and base MFN duty rates are not touched. CAPE is an IEEPA-only instrument.

Two things to internalize before anything else. Refunds are not automatic. CBP will not proactively send checks, and the tool is designed so that a filer has to raise their hand for each entry. And Phase 1 is a starting line. Harder scenarios are expected to arrive in later phases that CBP has not yet scoped or dated.

Phase 1 eligibility

CBP's ACE Portal CAPE Declarations Quick Reference Guide (Publication No. 5514-0426) sets out the rules directly. Every entry on a Declaration has to clear each of the following before CBP will accept it:

• Entry Summary Status must be Accepted in ACE
• Control Status must be CBP
• At least one IEEPA HTS line, meaning a Chapter 99 code in the 9903.01.xx or 9903.02.xx series, and those IEEPA lines must be properly valued on the underlying entry summary
• Not flagged for Reconciliation, not an Entry Type 08 (Duty Deferral), 09 (Reconciliation Summary), 23 (TIB), or 47 (Drawback), and no drawback claim designated against the entry
• No open or suspended protests on the entry, and for AD/CVD merchandise, no pending Commerce liquidation instructions
• Unliquidated, or liquidated no more than 80 days ago, so CBP can still reliquidate under the voluntary reliquidation authority at 19 U.S.C. §1501
• IOR on the ACE account matches the IOR on the underlying entry summary
• For Filer (Importer type only) and Organizational Broker accounts, the first three characters of the entry number match the account's Filer Code
• CSV built from CBP's template (ACEP_CapeEntryNumberUploadTemplate.csv), under 1 MB, with no duplicate entry numbers, and no more than 9,999 entries per Declaration

Only the IOR, or the authorized broker who originally filed the entry on that IOR's behalf, can submit a CAPE Declaration. Downstream parties who absorbed the IEEPA cost via contract cannot file. They will need to settle with the IOR privately.

Entries that fail validation are removed from the Declaration with a specific rejection reason per entry, while the valid entries on the same Declaration continue processing. A rejected entry is not forfeited. The filer can fix the error and resubmit it on a fresh Declaration.

One hard rule is worth emphasizing. Each entry can live on only one accepted CAPE Declaration. CBP has not published a mechanism to amend, withdraw, or cancel an accepted Declaration, so a sloppy acceptance is permanent. A rejection is recoverable. An acceptance with bad data is not.

How the refund actually gets paid

In a court filing in Atmus Filtration Inc. v. United States, CBP outlined the back end. The CAPE processing pipeline runs Monday through Thursday each week. Accepted entries are updated to a new version, routed through CBP review, and then liquidated or reliquidated. CBP is targeting roughly 45 days from Declaration acceptance to liquidation, and the importer-facing window published in its FAQ is 60 to 90 days from acceptance to the refund landing in the bank, unless a compliance concern triggers further review.

Refunds are consolidated two ways: by IOR (or by the party designated on CBP Form 4811) and by liquidation date. A single Declaration covering 400 entries across three liquidation dates produces three ACH payments, not four hundred. That consolidation is the whole point of the "Consolidated" in CAPE.

Interest is included in the consolidated refund. CBP has said in court filings that later CAPE phases will add the capability to process more complex interest calculations tied to multiple collection dates on a single entry summary. Phase 1 handles the simpler case.

ACH prerequisite

The operational detail to get right before anything else: CAPE refunds cannot be paid without valid ACH enrollment in the ACE Portal.

Under the Electronic Refunds Interim Final Rule, published January 2, 2026, effective February 6, 2026, implementing Executive Order 14247, CBP stopped issuing paper check refunds entirely. ACE Portal account holders can no longer submit paper ACH enrollment forms to the Revenue ACH Refund Support helpdesk. All enrollments and updates now flow through the ACH Refund Authorization tab in the ACE Secure Data Portal, where Trade Account Owners with an importer sub-account can add and update U.S. bank information directly.

Since the February 6 cutover, CBP has reported that more than 12,300 certified refunds have already been rejected because the recipient did not have valid U.S. bank account information on file in the ACE Portal. If CAPE accepts your Declaration and the refund bounces, CBP does not mail a check. The payment sits in the queue until the banking is corrected, and every week of that delay is a week you are financing CBP.

Two things to verify this week:

• Your ACE Portal account is active, with at least one Trade Account Owner who can manage the ACH Refund Authorization tab. Importer banking lives on the importer sub-account, not the broker sub-account.
• Your bank information in the ACE Portal is current, and your CBP Form 4811 designation routes refunds to the account you actually expect.

The backstory behind IEEPA tariffs

Throughout 2025, the Trump administration used the International Emergency Economic Powers Act, a 1977 law meant for sanctions and emergency export controls, to impose two tariff packages. The first was the "trafficking" tariffs on China, Canada, and Mexico, justified as a response to fentanyl flows. The second was the "reciprocal" tariffs announced in April 2025, a 10% baseline on almost every country with much higher rates on dozens of others.

Importers and small businesses sued. On August 29, 2025, the Federal Circuit ruled the tariffs unlawful. On February 20, 2026, in Learning Resources, Inc. v. Trump (No. 24-1287), the Supreme Court affirmed 6–3 that IEEPA does not give the President the power to impose tariffs. That authority belongs to Congress under Article I. The administration replaced the IEEPA tariffs the same day with a 10% global tariff under Section 122 of the Trade Act of 1974, capped at 15% and 150 days. Section 232 steel and aluminum, Section 301 China, and other statutory tariffs were not affected.

The Supreme Court's ruling invalidated the tariffs but did not spell out how the money already collected was supposed to come back. That fell to the U.S. Court of International Trade, where Senior Judge Richard Eaton was already handling Atmus Filtration Inc. v. United States. Judge Eaton issued an initial refund order on March 4, 2026, a further order on March 20, and an amended order on March 27 that directed CBP to address even finally liquidated entries while giving the agency time to actually build something. That something is CAPE.

How to prepare: submission is just the start

Takeaway. April 20 is not a finish line. It is the day you raise your hand and say please refund me. What decides whether you keep the money is the audit CBP does on your entries before it cuts the check. Your job between now and then is to make every entry defensible before you put it into a claim.

CBP is going to audit your claim before paying it. In a court filing in Atmus Filtration Inc. v. United States, CBP said it "still requires a review period to ensure no violation of other Customs laws and no other duties, taxes, or fees are owed (e.g., antidumping duties, Section 301 duties, Section 232 duties, etc.)." Every CAPE Declaration you file is a clean, curated list of your IEEPA-era entries, and CBP will audit that list. HTS classification, declared value, country of origin, Incoterms, related-party pricing, preference program claims, MPF and HMF math, all of it. If you overpaid IEEPA but underpaid anything else, the refund can be reduced, zeroed, or turned into a bill. A sloppy entry can pull the thread on penalties, prior disclosures, or a formal audit.

CBP also has reason to think the IEEPA era was unusually fraud-prone. On April 7, 2026, the New York Times published an investigation by Ana Swanson, "'Definitely a Sham': As Tariffs Climb, Trade Fraud and Accounting Tricks Proliferate", which reported, based on ImportGenius data, that the average declared value of a 20-foot container arriving from China dropped by nearly 40% between January 2025 and February 2026, while container values from other origins stayed flat. Flexport CEO Ryan Petersen told the Times, "We're seeing just total, rampant fraud," and separate Bloomberg reporting in February 2026 documented a $112 billion gap between what China said it exported to the U.S. and what CBP recorded arriving. CBP spokeswoman Trish Driscoll told the Times that "duty evasion schemes can be used to drive down declared customs values," and CBP is pattern-matching on exactly that data. A CAPE Declaration is the curated list of IEEPA-era entries CBP would otherwise have to assemble on its own.

Do not assume CBP cannot look closely. They already are, and they are getting better fast.

A common objection we hear: "Customs does not have the capacity to scrutinize every entry. They will just rubber-stamp refunds." The data says otherwise, on every dimension that matters.

The audit pace has already accelerated dramatically. CBP publishes audit results in its monthly operational updates, and the numbers tell a clear story. In March 2025 alone, CBP completed 71 audits and identified $310 million in duties and fees owed. For context, in the entire prior fiscal year, CBP collected $117.67 million from 417 audits. By April 2025, roughly halfway through the fiscal year, CBP had already completed around 200 audits and reached $134 million, a record pace. In May 2025, another 67 audits identified $139 million more. This is not business as usual. Multiple major trade law firms have noted that CBP's posture has shifted from trade facilitation to trade enforcement, a structural change they expect to continue and accelerate in 2026, driven by CBP's investment in AI.

The optimal move: audit before you claim. Audit every impacted entry to a standard you could defend to CBP cold, before it ever goes into a Declaration. No surprise bills. No penalty. No give-backs.

The short playbook for the days between now and April 20:

• Confirm ACE Portal access and ACH banking now. Active account, importer sub-account, valid U.S. bank information on the ACH Refund Authorization tab, and a CBP Form 4811 designation that matches where you actually want refunds to land. Do not leave this for April 20.
• Sort every IEEPA-era entry into one of the four buckets. Phase 1 ready, accepted but refund deferred, protest track, or later phase. Entry type, liquidation status, AD/CVD suspension state, and days past liquidation all matter.
• Audit before you claim. Assume CBP will run your entry data against its own revenue-enforcement targets once you file. Clean up HTS classification, value, country of origin, and program claims on your own schedule, not after a review lands. A post-summary correction or prior disclosure filed now is a different conversation than a CF-28 that shows up four months later.
• Centralize across brokers. If your IEEPA entries were filed across two, three, or ten brokers, do not leave each broker to run its own CAPE claim on its own schedule. No single broker has visibility into the others. Designate one internal owner or one lead trade advisor to run point and apply the same audit standard to every entry.
• File protective protests on the 180-day cliff. For any liquidated entry approaching the protest window, talk to counsel about filing a protest as a protective measure now. The window under 19 U.S.C. §1514 does not pause for CAPE.

This is not a one-time event

CAPE Phase 1 is the most visible near-term test of an importer's trade compliance infrastructure, and it is not the last one. Phase 2 is coming. Drawback-designated entries, AD/CVD entries with Commerce liquidation instructions, and finally liquidated entries still have to be addressed. Post-entry audits, prior disclosures, and ruling requests are not slowing down. Whatever an importer builds or buys to handle the April 20 filing is the same infrastructure that carries through every refund event, enforcement action, and audit response after it.

The importers who will recover the most on April 20 and the weeks that follow are the ones who already know which of the four buckets every entry belongs in before the portal opens, and who already have the audit work done on the ones they plan to file. The ones who start learning any of this in May will be waiting in line behind them.

What Pax can help you with

Pax does the preparation work so that submitting a CAPE Declaration is the last step, not the whole project. Our IEEPA Assist package covers the full pre-filing workflow:

• Audit before you claim. We review every impacted entry against CBP's Phase 1 validations and surface classification, valuation, country-of-origin, and program-claim risk before anything goes onto a Declaration.
• Sort entries into the four buckets. Phase 1 ready, accepted but refund deferred, protest track, and later phase. You see exactly which entries belong on the first Declaration and which do not.
• Dashboard analytics across brokers. If your IEEPA entries are spread across multiple brokers, Pax consolidates the view so one owner can run the whole program instead of chasing broker-by-broker status.
• One-click CAPE CSV. When you are ready to file, Pax generates the ACEP_CapeEntryNumberUploadTemplate.csv for each Declaration, under the 9,999-entry cap, with no duplicates, ready to upload.

Only the IOR or the authorized broker who originally filed each entry can submit a CAPE Declaration, so the upload itself happens inside your ACE Portal. We will walk through the submission with you on a call, or, if you grant Pax full ACE access for declarations under your importer account, we can handle the upload directly.

Book a call to learn more about our IEEPA Assist package.