U.S. Customs and Border Protection Launches CAPE Platform to Process IEEPA Tariff Refunds

Update (June 2026): Since the launch of CBP’s CAPE platform, additional trade litigation has introduced further complexity into the tariff refund landscape. On May 7, 2026, the U.S. Court of International Trade held that the Trump administration’s 10% global tariffs imposed under Section 122 of the Trade Act of 1974 were unlawful, finding that the statutory requirements for invoking that authority were not met. While the decision currently applies only to the specific plaintiffs and does not provide universal relief, it signals continued judicial scrutiny of recent tariff actions and may expand the scope of potential refund opportunities over time. Importers should remain attentive to ongoing appeals and procedural deadlines, as these developments could affect both eligibility for refunds and the strategic use of platforms like CAPE.

Introduction

U.S. Customs and Border Protection (“CBP”) has formally launched Phase 1 of the Consolidated Administration and Processing of Entries (CAPE) platform as of April 20, 2026. CAPE is CBP’s long-awaited electronic mechanism for administering refunds of tariffs imposed under the International Emergency Economic Powers Act (IEEPA) following recent court decisions that invalidated those tariffs.

For many import-dependent manufacturers, IEEPA duties represented a material cost over the past several years. CAPE now establishes a standardized pathway for requesting refunds; however, the process is phased, highly procedural, and subject to important eligibility limitations. Understanding which entries qualify and what actions are required now will be critical to maximizing potential recoveries while avoiding delays.

What CAPE Phase 1 Does

CAPE Phase 1 allows eligible importers or their customs brokers to submit IEEPA duty refund requests electronically through the ACE Secure Data Portal. Submissions are made via a structured CSV upload known as a CAPE Declaration, which lists the entry numbers for which refunds are being requested.

Once submitted and validated by CBP:

• ACE removes the IEEPA Chapter 99 tariff lines from qualifying entries
• Duties are recalculated without IEEPA tariffs
• Entries are liquidated or reliquidated as appropriate
• Refunds are ultimately issued and consolidated by recipient and liquidation date

This process replaces earlier expectations that refunds might occur automatically and confirms that affirmative action by importers is required.

Entries Covered in Phase 1

Phase 1 is intentionally limited in scope and currently applies to the following categories of entries:

• Unliquidated entries
• Entries liquidated within approximately 80 days prior to filing
• Entries with a status of suspended, extended, or under review
• Warehouse and warehouse withdrawal entries (refunds issued after liquidation)
• CBP has explained that this scope is designed to align with its statutory reliquidation authority and current court directives.

Entries Not Eligible in Phase 1

Many entries commonly held by global manufacturers will not be processed during this initial phase. These include:

• Entries covered by an open protest
• Entries flagged for reconciliation
• Entries included in drawback claims
• Entries that have reached final liquidation
• Certain entries subject to antidumping or countervailing duties (AD/CVD)

CBP has indicated that these categories are being evaluated for future CAPE phases, but no formal timeline has been announced.

How Refunds Will Be Paid

All approved IEEPA refunds will be paid electronically via ACH. To receive refunds, importers (or designated “notify” parties for example brokers or agents that are officially designated by an importer of record) must have refund-specific ACH banking information on file in ACE. This refund enrollment is separate from ACH payment information used to remit duties, and missing or incorrect enrollment may delay receipt of funds.

Refund activity and rejected payments can be monitored through standard ACE refund reports.

Practical Considerations for Importers

While CAPE represents meaningful progress, it does not resolve all outstanding IEEPA refund issues. Importers should expect a phased, multi-step recovery process, particularly for older or fully liquidated entries. Companies should also be aware that CBP has expressly stated that the only avenue for refunds is via proper CAPE submissions.

From an accounting and planning perspective, companies will ultimately need to determine how to treat cash receipts, as income or reduction of inventory cost.  Currently the status of potential refunds has been unclear and therefore the appropriate financial statement treatment for expected, but not yet issued refunds, has not been determined.  Similarly tax authorities have not ruled as to how the cash receipts will be treated for income tax purposes.

Recommended Next Steps

We recommend that affected importers take action now by:

• Identifying entries subject to IEEPA duties and confirming the accuracy of the liquidation status in ACE
• Ensuring ACH refund enrollment specific to CAPE is active and accurate
• Where applicable, coordinating closely with customs brokers on CAPE preparation and submission
• Segregating ineligible entries for tracking for future opportunities

Our firm is actively assisting multinational manufacturers and distributors related to tax and accounting considerations for potential IEEPA duty recoveries. Please contact your engagement team if you would like support assessing your accounting and tax issues related to these potential recoveries or if you need help getting connected with a resource for preparing for CAPE filings.

About the Writer

David Jones, Partner
Email: [email protected]

David is a partner in GreerWalker’s tax practice with 15 years of experience providing tax planning and compliance services to manufacturing, distribution, and global services companies. His expertise includes international taxation, transfer pricing, and customs-related tax matters affecting importers and exporters, making him uniquely qualified to guide clients through complex tariff refund situations.