April 1, 2026

Customs Reports Additional Progress on CAPE System and Further Defines Limitations for Phase 1 of IEEPA Tariff Refunds

Husch Blackwell LLP + Follow Contact LinkedIn Facebook X Send Embed On March 31, 2026, Brandon Lord, the Executive Director of the U.S. Customs and Border Protection (“CBP” or “Customs”) Trade Programs Directorate, Office of Trade, filed a status update (the “Declaration”) with the Court of International Trade (“CIT”) further outlining Customs’ progress in developing the Consolidated Administration and Processing of Entries (CAPE) functionality within ACE. CAPE has four integrated components: Claim Portal, Mass Processing, Review and Liquidation/Reliquidation, and Refund. According to the Declaration, the following progress has been made on each of those components since the last declaration filed on March 19, 2026:

• Claim Portal: Customs has completed majority of the core development and estimates the Claim Portal is 85% complete.

• Mass Processing: Customs has “significantly developed” the portal’s ability to process entry summaries identified on a CAPE Declaration in the Mass Processing component, which will allow Customs the ability to modify entry summaries as required. Customs estimates the Mass Processing component is approximately 60% complete.

• Review and Reliquidation: Customs continues to test the liquidation/reliquidation function in CAPE and estimates the development of this portion of the portal is approximately 80% complete.

• Refund: Customs is currently focused on testing the Refund portion of the portal and estimates it is approximately 75% complete.
  The Declaration clarifies that refunds will be issued electronically to the importer of record “or a party the IOR has designated to receive refunds on its behalf on a CBP form 4811.” We believe this means that if an IOR is transferring the refund right to a third-party, then that third-party must also be able to receive the refunds electronically via ACE.

Significantly, work on the CAPE functionality’s Mass Processing component is currently limited to entries that are either unliquidated or for which the statutory 90-day voluntary reliquidation period has not expired. CBP has been clear that the timeline for the current Phase 1 deployment does not cover the inclusion of finally liquidated entries. The Declaration further explains what types of entries will not be covered under Phase 1 of the phased refund approach. These entry types include:

• Entries flagged for reconciliation, including Entry Type 09 – Reconciliation Summary;
• Entries designated on a drawback claim;
• Entries covered by an open protest;
• Entries not filed in ACE, and entries without a liquidation status in ACE; and
• Entries subject to AD/CVD for which Department of Commerce has issued liquidation instructions that are pending liquidation in accordance with 19 U.S.C. § 1504(d). Customs further states that it intends to develop functionalities to address refund collections for more complex entries, such as those listed above, as well as entries for which liquidation is final. However, Customs did not provide a timeline for when it anticipates such functionalities will be available.

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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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