Changeflow GovPing Trade & Sanctions CBP Commences Processing IEEPA Tariff Refunds v...
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CBP Commences Processing IEEPA Tariff Refunds via CAPE Portal Starting April 20, 2026

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Summary

U.S. Customs and Border Protection (CBP) commenced processing IEEPA tariff refund applications on April 20, 2026, through a new online portal called Consolidated Administration and Processing of Entries (CAPE). Phase 1 covers unliquidated entries and entries within 80 days of their liquidation date; other categories including entries under Protest, subject to Drawback claims, or pending AD/CVD proceedings are excluded until Phase 2. Importers must preregister in the ACE portal and submit CSV files listing up to 9,999 entries per declaration; only the Importer of Record or the broker that originally filed the entries may submit the CAPE Declaration.

“Phase 1 of CBP's refund processing will cover unliquidated entries and liquidated entries within 80 days of their liquidation date; other categories of entries will be handled in a Phase 2.”

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What changed

CBP has implemented the CAPE portal for processing IEEPA tariff refunds following the Supreme Court's ruling that such tariffs were unlawful. Phase 1 processing covers unliquidated entries and entries liquidated within 80 days; entries under Protest, subject to Drawback claims, reconciliation flags, not filed in ACE, or subject to AD/CVD proceedings are excluded pending Phase 2. Importers seeking refunds must preregister in the ACE portal with banking details under the ACH Refund Authorization tab, and must submit entry lists using CSV format (up to 9,999 entries per CAPE Declaration). Third parties other than the IOR or original broker may not file CAPE Declarations. CBP anticipates 45 days for review and 60-90 days for the electronic ACH refund to be received, with interest of approximately 6% on duties, taxes, and fees.

Importers that paid IEEPA tariffs on entries now eligible for refund should confirm their ACE portal registration is complete and ensure their entry lists are formatted per CBP's CSV requirements before submission. Firms with entries falling outside Phase 1 (protested, subject to drawback, or AD/CVD-related entries) should monitor for Phase 2 processing timelines. The 6% interest component may be material for large-volume importers and should be factored into refund calculations.

Archived snapshot

Apr 27, 2026

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April 27, 2026

U.S. Customs and Border Protection Commences Processing Refund Applications for IEEPA Tariffs Starting April 20, 2026

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On Monday April 20, 2026, the U.S. Customs and Border Protection commences processing refund applications for IEEPA tariffs paid by importers but ruled unlawful by the U.S. Supreme Court earlier this year.  This online process will be implemented through a new online portal called the Consolidated Administration and Processing of Entries (“CAPE”).  Summarized below is the overall process for what clients can expect when CAPE commences operations next week.  Please note the CSV format requirements for entry lists in the CAPE Declaration, which CBP has stipulated in recent days.

  1. All importers due tariff refunds must preregister for electronic refunds with CBP by adding their banking details under the ACH Refund Authorization tab in the ACE portal.

  2. Phase 1 of CBP’s refund processing will cover unliquidated entries and liquidated entries within 80 days of their liquidation date; other categories of entries will be handled in a Phase 2.

  3. The entries that will not be handled in phase 1 refund processing, include:

•Entries covered by an open Protest;

•Entries subject to a Drawback claim;

•Entries flagged for reconciliation;

•Entries not filed in ACE;

•Entries subject to AD/CVD proceedings and pending liquidation.

  1. Earlier CBP guidance stated that the Importer of Record (“IOR”) may authorize third parties to file CAPE Declarations for refunds, however CBP officials have in more recent days stated that only the IOR or the broker that originally filed the entries now being submitted for refund may submit the CAPE Declaration.

  2. Use only the CSV (Comma-Separated Values) file format for your list of IEEPA entries subject to refund.  The list may be up to 9,999 entry numbers long; additional CSV entries may be submitted on a separate CAPE Declaration.

  3. Once CBP has validated the correct applicant and format, it will generate a CAPE Claim Number.

  4. CBP anticipates that its review shall take about 45 days after submission for processing and liquidation or re-liquidation of a particular entry.  An actual electronic ACH refund will occur 60-90 days after the original date of submission.

  5. Refunds will be calculated to include duties, taxes, and fees, plus interest of about 6%.

  6. Naturally, all of the above is subject to verification under real world conditions once CAPE commences operation, and time will tell.

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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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Named provisions

CAPE Declaration ACH Refund Authorization

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Last updated

Classification

Agency
Buchalter
Published
April 20th, 2026
Instrument
Notice
Branch
Executive
Legal weight
Non-binding
Stage
Final
Change scope
Minor

Who this affects

Applies to
Importers and exporters
Industry sector
4231 Wholesale Trade
Activity scope
Tariff refund processing Customs administration Trade remedy procedures
Geographic scope
United States US

Taxonomy

Primary area
International Trade
Operational domain
Compliance
Topics
Taxation Administrative Law

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