Please note that the information provided in this article is current as of April 17, 2026.
Key Takeaways
|
Recent court rulings have overturned the IEEPA tariffs previously imposed under the International Emergency Economic Powers Act (IEEPA). For importers, this is an opportunity to recover overpaid customs duties. To facilitate refunds, the U.S. Customs and Border Protection (CBP) created a digital tool known as the Consolidated Administration and Processing of Entries (CAPE) in the Automated Commercial Environment Secure Data Portal (ACE Portal) for importers to submit refund requests beginning Monday, April 20th at 8 AM EST. To submit their claims, importers must meet specific eligibility requirements and follow all instructions to ensure claims are processed without delays.
The CAPE refund process is being pushed out in phases. According to the CBP, “Phase 1 is limited to certain unliquidated entries and certain entries within 80 days of liquidation” (CBP). Phase 1 goes live on April 20, 2026, at 8 AM EST.
IEEPA Tariffs and Refund Eligibility
What are IEEPA tariffs?
The International Emergency Economic Powers Act grants the president authority to regulate commerce during declared national emergencies. On April 2, 2025, President Donald Trump declared a national emergency in which specific tariffs were levied on various imported goods. On February 20, 2026, the U.S. Supreme Court ruled that the IEEPA does not authorize tariffs and the collected tariffs must be returned to the importers.
Eligibility Requirements for Importers
To secure a refund, importers must meet specific criteria, such as only claiming refunds for tariffs paid under the invalidated IEEPA framework. Also, only the Importer of Record (IOR) or the licensed customs broker can file a CAPE Declaration. All refund amounts requested must be entirely accurate and match your entry data. Any discrepancies in the valuation, classification, or country of origin can result in rejected claims.
Consolidated Administration and Processing of Entries (CAPE)
What CAPE Means for Your Refund
CAPE is a brand new functionality within the Automated Commercial Environment (ACE) to streamline the submission and processing of valid refund requests for duties imposed under IEEPA.
What is the Purpose of CAPE?
Instead of handling the refunds on an entry-by-entry basis, CAPE consolidates this process. This system was designed to consolidate refunds of the IEEPA duties, including any interest, directly to the Importer of Record (IOR) or their designated recipient.
Phased Implementation of CAPE
CBP is not releasing all system capabilities at once; they are utilizing a phased development approach. Phase 1 of the CAPE system launches on April 20, 2026. This phase only accepts certain unliquidated entries and specific entries that fall within 80 days of the liquidation date. Future phases will accommodate more complicated entry types, the CBP has not released when those phases will be implemented.
Navigating the ACE Portal for IEEPA Refunds
The ACE portal is required to submit and receive tariff refunds. Importers of Record and authorized customs brokers will file their declarations directly through their ACE Secure Data Portal Accounts.
What You Need Before Filing
Before attempting to file a claim, the Importer of Record or the authorized customs broker must have an active ACE Portal account. Additionally, all refunds will be distributed electronically. Within the ACE Portal, the IOR or the customs broker will provide the CBP with the ACH bank information. If this information is missing, CBP will hold the refund until the banking details are supplied.
How to Submit Your CAPE Declaration
Once your account has been set up, you can begin the submission process.
According to CBP,
“Importers of Record (IORs) and Customs brokers will be able to file a CAPE Declaration, using a Comma-Separated Values (.CSV) file, through their web-based ACE Secure Data Portal (ACE Portal) account. Filers will not use the Automated Broker Interface (ABI) to file a CAPE Declaration.
The CAPE Declaration consists of the list of entries for which refunds of IEEPA duties are being requested. CBP will not require any other information in the .CSV file. Each individual CAPE Declaration has a limit of 9,999 entries. IORs and brokers can file multiple CAPE Declarations. The CAPE Declaration template file will be available through the “Upload” button in the CAPE tab” (CBP).
What is the Difference Between Unliquidated and Liquidated Entries?
The classification of your customs entries, whether unliquidated or liquidated, is important, as this status fundamentally dictates the necessary process and potential complexity for obtaining your IEEPA tariff refund.
Unliquidated Entries
Unliquidated entries remain open in the customs system and are under review where the duty, tax, and fee assessments are not finalized. These duties are eligible for refund to the IOR or their customs broker.
Liquidated Entries
Liquidated entries have already completed the liquidation process. If the entry falls within 80 days of the liquidation date, they are in phase 1 of the refund process. The CBP has not announced if and when the other phases will happen and how they will handle the specific historical claims.
When will I get my refund?
According to CBP, importers or authorized brokers should anticipate that valid IEEPA refunds will be issued within 60 to 90 days following the acceptance of a CAPE Declaration. The CBP does note this timeline should be accurate unless a compliance concern triggers a CBP review or a court order changes this.
Connect with LogiWorld
Securing your IEEPA tariff refunds requires a proactive approach. You must verify your ACE portal access, confirm your banking details, and carefully upload your entries to the portal. By preparing your documentation now, you position your business to capitalize on these refunds as soon as the CAPE systems accept your declaration.
At LogiWorld, our team understands the complexities of customs brokerage and global trade. If you have any questions about the IEEPA tariff refund process, please reach out to our customs team. We will continue to monitor developments and provide updates as the CBP updates the instructions and phases for getting a refund.
Resources:
https://www.cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds
https://www.cbp.gov/trade/automated/ace-portal-and-ach-refunds-faqs
https://www.cbp.gov/trade/programs-administration/trade-remedies
https://www.congress.gov/crs-product/R45618
https://www.cbp.gov/sites/default/files/2026-04/ace_portal_-_cape_declarations_508c.pdf https://www.whitehouse.gov/fact-sheets/2025/04/fact-sheet-president-donald-j-trump-declares-national-emergency-to-increase-our-competitive-edge-protect-our-sovereignty-and-strengthen-our-national-and-economic-security/
