CBP Opens Portal for IEEPA Tariff Refund Claims
Summary
U.S. Customs and Border Protection launched Phase 1 of the CAPE refund process within the ACE portal on April 20, 2026, enabling importers to submit refund claims for tariffs imposed under IEEPA. Phase 1 covers primarily unliquidated entries and entries within approximately 80 days of liquidation, with electronic CAPE Declarations required in CSV format; accepted declarations yield consolidated refunds with interest within 60–90 days. Early portal issues have been reported, including account access difficulties and system error messages, which CBP is monitoring and addressing as it works to resolve defects.
“Under Phase 1, importers of record or their authorized customs brokers must submit CAPE Declarations electronically through ACE using a prescribed CSV format.”
Importers and their customs brokers should verify ACE portal access, electronic refund authorization, and ACH banking details are properly configured before the filing window opens, and should prepare CAPE Declarations in the prescribed CSV format in advance to account for reported portal performance issues. Phase 1 eligibility is limited to unliquidated entries and those approaching liquidation—firms with older, already-liquidated entries should monitor future CBP guidance for later phases that may extend recovery opportunities.
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What changed
CBP has opened the CAPE refund portal in the ACE system for submitting IEEPA tariff refund claims, effective April 20, 2026. This marks the beginning of the active claims phase following the Supreme Court's February 2026 ruling that IEEPA does not authorize tariff imposition and the subsequent Court of International Trade order requiring CBP to liquidate and reliquidate affected entries.
Importers of record and authorized customs brokers must prepare CAPE Declarations in a prescribed CSV format for electronically filing through ACE. Affected parties should verify their ACE portal access and electronic refund authorization are established, identify which entries fall within Phase 1 eligibility (unliquidated entries and those within approximately 80 days of liquidation), and coordinate with customs brokers early to account for reported technical delays. Future phases and additional entry categories will be addressed in subsequent CBP guidance and court orders.
What to do next
- Confirm which IEEPA‑affected entries fall within Phase 1 eligibility
- Ensure ACE portal access, electronic refund authorization, and ACH banking information are properly established
- Prepare CAPE Declarations in coordination with customs brokers, as appropriate
- Monitor CBP guidance and future court orders addressing later CAPE phases and additional entry categories
Archived snapshot
Apr 23, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
April 23, 2026
IEEPA Tariff Refunds Update: CBP Opens Refund Portal, Marking Start of Claims Phase
Kendall A. Schnurpel, Alex C. Wimmer Krieg DeVault + Follow Contact LinkedIn Facebook X ;) Embed
U.S. Customs and Border Protection (“CBP”) has opened the long‑anticipated online portal for submitting refund claims for tariffs imposed under the International Emergency Economic Powers Act (“IEEPA”), marking a significant transition from system development to active filings. While this launch allows importers to begin pursuing refunds through CBP’s Consolidated Administration and Processing of Entries (“CAPE”) platform, the rollout is phased and subject to operational constraints. Importers should not assume that refunds will occur automatically without affirmative action. 1
Background
As discussed in our prior alerts U.S. Trade Court Orders Refunds of Unlawfully Collected IEEPA Tariffs and IEEPA Tariff Refunds: Trade Court Sets March 19 Progress Deadline as CBP Builds CAPE Refund System, the U.S. Supreme Court held on February 20, 2026, that IEEPA does not authorize the imposition of tariffs. The U.S. Court of International Trade subsequently ordered CBP to liquidate and reliquidate affected entries without regard to IEEPA duties, while temporarily pausing immediate compliance to allow CBP time to develop a centralized refund mechanism implemented through ACE and CAPE. 2
What CBP Has Announced
CBP has announced the launch of Phase 1 of the CAPE refund process within the Automated Commercial Environment ("ACE") portal, effective April 20, 2026. Under Phase 1, importers of record or their authorized customs brokers must submit CAPE Declarations electronically through ACE using a prescribed CSV format. Phase 1 applies primarily to unliquidated entries and certain entries that are within approximately 80 days of liquidation. Once a CAPE Declaration is accepted, CBP will remove the IEEPA tariff provisions, liquidate or reliquidate the affected entries, and issue consolidated electronic refunds (with interest), generally expected within 60–90 days of acceptance. 3
Practical Note Regarding Early Portal Issues
Importers should be aware that, consistent with other large‑scale government system launches, some users have reported early‑stage access and performance issues following the initial deployment of the CAPE portal. Reported issues include account access difficulties, system error messages during submission, and delays associated with high filing volumes. CBP has publicly acknowledged that it is monitoring system performance and addressing defects as they arise, but importers are encouraged to begin preparation and submission early and to build in time for potential technical delays. 4
What You Should Do Now
- Confirm which IEEPA‑affected entries fall within Phase 1 eligibility.
- Ensure ACE portal access, electronic refund authorization, and ACH banking information are properly established.
- Prepare CAPE Declarations in coordination with customs brokers, as appropriate.
- Monitor CBP guidance and future court orders addressing later CAPE phases and additional entry categories. How We Can Help Krieg DeVault attorneys Kendall A. Schnurpel and Alex C. Wimmer continue to monitor CBP’s implementation of the CAPE refund process and related court proceedings. Importers with questions regarding portal eligibility, preparation of CAPE Declarations, coordination with brokers, liquidation timing, or strategies for maximizing recovery of unlawfully collected IEEPA duties are encouraged to contact Kendall A. Schnurpel, Alex C. Wimmer, or their regular Krieg DeVault attorney.
1 CBP guidance and public reporting announcing April 20, 2026 launch of CAPE Phase 1.
2 Learning Resources, Inc. v. Trump (U.S. Feb. 20, 2026); Atmus Filtration, Inc. v. United States (Ct. Int’l Trade Mar. 2026).
3 CBP CSMS #68315804 and related CBP trade guidance on CAPE filing requirements and timelines.
4 CBS News, "Tariff refund portal off to bumpy start as some businesses report glitches" (Apr. 20, 2026), and related trade press.
;) ;) Report
Related Posts
- March 19 CBP Hearing Shows Progress on IEEPA Refund System, but Key Questions Remain
- IEEPA Tariff Refunds: Trade Court Sets March 19 Progress Deadline as CBP Builds CAPE Refund System
- U.S. Trade Court Orders Refunds of Unlawfully Collected IEEPA Tariffs
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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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