CBP Activates Phase I IEEPA Refund Processing via ACE

April 21, 2026

IEEPA Update: Phase I Refunds Available Now

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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 the refund data. Once validated, the successful CAPE Declarations are then processed in mass, and refunds are issued directly to the importer’s ACH account.

Entries that are either unliquidated or have been liquidated after January 30, 2026, are eligible for refunds under Phase I. To ensure your CAPE Declaration is accepted, you must prepare a CSV file that contains a column of all relevant entry numbers under Phase I.

The CAPE tab in the ACE Portal is used to create and submit the CAPE Declaration with IEEPA entry numbers for refund. Below is a list of step-by-step directions to file a CAPE Declaration:

1. In the CAPE tab, in the default “File Uploads” subtab, select the “Upload” button.
2. In the “CAPE Upload” dialog box, select the “CAPE Upload Template” hyperlink.
3. This will download an Excel spreadsheet template file titled ACEP_CapeEntryNumberUploadTemplate. This template file will include one (1) column titled “Entry Number.” The header title in Column A, Row 1 of the spreadsheet cannot be missing.
4. Starting on the second row, enter the applicable entry number(s) for a maximum of 9,999 entries per CAPE Declaration. Each entry should be 11 alphanumeric characters. Dashes are optional.
5. Save this file as a “.csv” file. The system will reject all other types of files.
6. In the “CAPE Upload” dialog box, upload the newly saved .csv file.
7. The “CAPE Upload In Progress!” dialog box will confirm whether the upload was successful. If successful you may close this dialog box.
8. The file upload job displays in the “File Upload History” list. If applicable, the reason displays in the “File Upload Status” column. Otherwise, “Accepted” displays. Please note, entries falling into the categories below will not be accepted in Phase I:

• Entries covered by an open or suspended protest;
• Entries that have been flagged for reconciliation, as well as Entry Type 09 – Reconciliation Summary;
• Entries on a drawback claim;
• Entries not filed in ACE, and entries without liquidation status in ACE;
• Entries subject to Antidumping/Countervailing Duties (AD/CVD), for which the Department of Commerce has issued liquidation instructions, that are pending liquidation in accordance with 19 U.S.C. § 1504(d); and
• Entries for which liquidation is final.

CAPE System Functionality

The CAPE system operates in four parts:

Part 1: Claim Portal. The Claim Portal, accessible as a new tab in both importer and broker ACE Portal accounts, is where importers and brokers submit IEEPA refund requests (CAPE Declarations) to CBP. Submitted claims undergo two validation series: (1) file validations, which confirm the request contains all required information, is properly formatted, and that the submitter is the importer of record or authorized broker; and (2) entry validations, which confirm that the entry summary numbers in the submitted CSV exist in ACE and that an IEEPA Chapter 99 tariff was declared on each entry.

Part 2: Mass Processing. This component automatically removes applicable IEEPA tariffs and HTS numbers from validated entry summaries, then runs ACE duty calculation validations. It calculates duties owed (excluding IEEPA tariffs) and any applicable interest on refunds. Once complete, the system "accepts" the CAPE Declaration.

Part 3: Review and Liquidation/Reliquidation. The Review and Liquidation/Reliquidation component will initiate review and liquidation/reliquidation of the entries identified in the accepted CAPE declaration. It will automatically set entries to liquidate/reliquidate on a specified number of days from acceptance, and CBP can perform a manual review if needed at this stage.

Part 4: Refund Processing. Once a CAPE Declaration reaches its scheduled liquidation/reliquidation date, the Refund component feeds it through a CAPE-specific process within ACE Collections. Refunds are then disbursed electronically to the importer's designated bank account. Importers must have ACH information on file in ACE, or CBP will hold the refund until it is available. CBP's disbursement target is 45 days post-validation.

Next Steps

Importers with unliquidated entries or entries liquidated within the preceding 80 days should prepare a CSV file listing the entry summary numbers for which IEEPA duty refunds are being requested. Accuracy is critical: Importers should verify that each entry number is correct, that each entry is associated with an IEEPA HTS Code in Chapter 99, that there are no duplicates, and that no entries ineligible under Phase I are included. If a CAPE Declaration contains inaccurate or ineligible entries, ACE will reject the entry and your timeline to receive refunds may be delayed.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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