CBP Confirms CAPE —
The New System for
IEEPA Duty Refunds
U.S. Customs and Border Protection has filed detailed court documents outlining CAPE — Consolidated Administration and Processing of Entries — a new ACE module to automate refunds on $166 billion in IEEPA duties. No ABI required. CSV upload via web portal. Direct ACH payment to your bank account. System currently 40–80% developed, rolling out in phases.
CBP Executive Director
Trade Programs Directorate
On 6 March 2026, CBP's Executive Director of Trade Programs, Brandon Lord, filed a declaration with the U.S. Court of International Trade (CIT) confirming that CBP is building CAPE — Consolidated Administration and Processing of Entries — a new module within ACE to automate IEEPA duty refunds with interest. The CIT suspended its earlier refund order pending development. The system is projected to be ready within 45 days and will roll out in phases. As of 4 March 2026, over 333,000 importers have made more than 53 million entries on which approximately $166 billion in IEEPA duties have been deposited or paid.
The Mechanism
What CAPE Does — The Full Picture
CAPE is a new module within ACE designed to consolidate, validate, and process IEEPA refund submissions automatically. Here is exactly how it works — and why the submission mechanics matter for how you prepare.
Importers and customs brokers submit refund requests through a new ACE web portal by uploading CSV files of entry summaries. Critically, this does not require ABI (Automated Broker Interface) connectivity — meaning importers and brokers without ABI access are not locked out of the process. The submission route is accessible to any importer with ACE portal credentials and a correctly formatted CSV file.
Once submitted, CAPE automatically validates submissions, removes IEEPA fee fractions, recalculates fees, and processes settlement or re-liquidation to generate the refund. The system handles the entry-level calculation — but only as accurately as the data submitted. Entries with classification errors or missing documentation will produce understated refunds or fail validation.
Refunds are issued electronically and deposited directly into your designated bank account via ACH. Since 6 February 2026, CBP is required to issue all refunds electronically. If your bank account is not registered for ACH refunds with CBP, your refund will be rejected when issued. This registration must be completed before CAPE goes live — it cannot be done retroactively after your refund is processed.
The CSV submission requires organised entry summary data for every entry on which IEEPA duties were paid: entry numbers, HTS classifications, countries of origin, IEEPA duty amounts paid, and supporting documentation references. Importers who have not identified and organised this data before Phase 1 opens will be unable to submit accurately at rollout. This is the preparation work MyCustomsInfo® performs now, before CAPE goes live.
The CBP Declaration
The Four-Step Refund Process as Filed
As outlined in Brandon Lord's declaration to the CIT on 6 March 2026.
Importer Files a Declaration in ACE Listing IEEPA Duty Entries
The importer files a declaration in ACE listing every entry on which IEEPA duties were paid. Under the CAPE implementation, this is done via CSV upload through the new ACE web portal — no ABI connection required. The completeness and accuracy of this submission determines the maximum refund available. Entries not included cannot be recovered at this stage.
CBP Validates Each Entry and Calculates IEEPA Tariffs Paid Including Interest
CBP validates each submitted entry and calculates the IEEPA tariffs paid, including interest. CAPE automatically removes IEEPA fee fractions and recalculates fees. Entries with classification inconsistencies, valuation errors, or missing origin documentation are at risk of producing understated calculations or failing validation entirely.
ACE Automatically Finalises, Liquidates, or Re-Liquidates the Entries
ACE automatically finalises or liquidates or re-liquidates the relevant entries to process settlement. This is how entries that have already been liquidated re-enter the refund cycle. However: the declaration is silent on entries that are liquidated and outside the protest period. Whether these entries can be re-liquidated through CAPE remains unresolved — see the critical alerts section below.
Treasury Issues Electronic Refunds of the Aggregate Total — With Interest
CBP certifies the aggregate refund amount per importer. The Department of the Treasury then issues electronic refunds of the aggregate total — paying per importer rather than per entry summary. Refunds include interest and are deposited directly via ACH into the importer’s designated bank account. ACH registration with CBP is required before this step can complete.
Rollout Status
Where CAPE Is Now — and What Rolls Out First
The system is in active development. The phased approach means some importers will be able to submit before others — those with straightforward entry types first.
CBP projects the system will be ready within 45 days of 6 March 2026 — placing the estimated rollout around late April 2026. The CIT has ordered a progress report by 19 March 2026 and is maintaining active oversight. Whether CBP meets the 45-day target remains to be confirmed.
Most Formal and Informal Entries Where IEEPA Fees Were Paid
Phase 1 will cover the majority of standard import entries — both formal entries (typically commercial shipments over $2,500) and informal entries — where IEEPA duties were paid. If your IEEPA exposure is concentrated in standard commercial imports, you are likely in Phase 1 scope and should be preparing your CSV data now to submit at the earliest opportunity.
Complex Entry Types — To Be Defined as Development Progresses
More complex entry types — including entries involving special procedures, bonded warehouse withdrawals, drawback entries, and other non-standard classifications — will be addressed in later phases. CBP has not yet defined the full scope of Phase 2 and beyond. Importers with complex entry mixes should monitor CBP guidance as each phase is announced and prepare the relevant entry data in advance.
Critical Issues
Three Things That Cannot Wait for CAPE to Launch
Two of these three issues will block your refund entirely if not resolved before CAPE goes live. One may cause you to permanently lose eligibility on historical entries.
Protest Window — Silent in the Declaration, Closing Now on Some Entries
The Brandon Lord declaration is entirely silent on entries that are already liquidated and outside the protest period. It is currently unknown whether CAPE will cover these entries through the re-liquidation mechanism in Step 3. Importers with IEEPA entries that are approaching or already past the protest deadline should monitor liquidation dates immediately and consider filing protests with CBP before the window closes. The standard protest period under 19 USC 1514 is 180 days from the date of liquidation. Once this window closes, the opportunity to seek a refund on those entries may be permanently lost — regardless of what CAPE ultimately covers.
ACH Refund Registration — Required Before Your Refund Can Be Paid
Since 6 February 2026, CBP is required to issue all refunds electronically. The declaration confirms that many importers have not registered for ACH electronic refunds — meaning their refunds will be rejected at Step 4 until registration is completed. Register your bank account for ACH refunds with CBP now — this is an administrative task that should be done this week, not at rollout. Keep your ACE portal credentials current at the same time.
ACE Credentials and CSV Data — Must Be Ready Before Phase 1 Opens
CAPE submission requires an active ACE portal account with current credentials and a correctly formatted CSV file of entry summaries. Importers who have not identified their IEEPA-affected entries and organised the required data will not be able to submit at Phase 1 launch. In a staged rollout, first movers are processed first. Importers who submit accurately at launch will receive refunds before those who wait or submit incomplete data.
Your Action Plan
Four Things to Do Before CAPE Goes Live
Start these steps now. The protest window and ACH registration issues exist today — not at rollout.
Register Your Bank Account for ACH Electronic Refunds
Log into your ACE portal and confirm your bank account is registered for ACH refund payments. If it is not, complete the registration process now. Since 6 February 2026, CBP can only issue refunds electronically — an unregistered account means your refund is rejected when issued.
Confirm Your ACE Portal Credentials Are Current
Verify that your ACE portal account is active and your login credentials are valid. The CSV submission in Step 1 of the CAPE process requires an active ACE account. Expired or inactive accounts will prevent submission at launch.
Identify IEEPA-Affected Entries and Monitor Protest Deadlines
Pull your full import history and identify every entry on which IEEPA duties were paid. For each entry, note the liquidation date and calculate whether the 180-day protest window is still open. Entries approaching the protest deadline should be reviewed urgently — file protests before the window closes on any entry where CAPE eligibility is uncertain. MyCustomsInfo® performs this identification automatically across your full entry history.
Prepare and Validate Your CSV Entry Data for Phase 1 Submission
Organise your IEEPA-affected entries into the CSV format CAPE will require: entry numbers, HTS classifications, countries of origin, and IEEPA duty amounts paid per entry. Validate classifications and valuations before submission — errors in the CSV produce understated refunds or validation failures at Step 2. Monitor CBP’s detailed user guidance as Phase 1 approaches for the exact CSV specification.
MyCustomsInfo® & CAPE
Built for Every Step of the CAPE Process
The MyCustomsInfo® portal was designed to perform the three core functions the CAPE submission process requires across Steps 1 through 4.
Identify IEEPA-Affected Entries & Build Your CSV
MyCustomsInfo® ingests your full import declaration history, maps every entry against IEEPA tariff schedules by HTS code and country of origin, calculates the refundable duty per entry including interest, and flags protest window deadlines. The output is a validated, submission-ready dataset — the CSV CAPE requires for Step 1, built before the portal opens.
Validate Classifications & Maximise Refund Accuracy
CAPE calculates refunds based on what you submit. Errors in HTS classification or valuation produce understated refunds at Step 2. MyCustomsInfo® reviews classifications against the IEEPA tariff schedule, identifies entries where the declared code produced a higher duty than correct classification would have done, and corrects the data before submission — maximising the refund calculated by CBP.
Manage Submissions, Track Status & Monitor Payments
Once CAPE is live, MyCustomsInfo® tracks each submitted entry through Steps 2, 3, and 4, manages CBP correspondence, flags documentation requests, and monitors ACH payments against expected recovery per entry. Full audit trail from CSV submission to Treasury payment — with confirmation that the aggregate refund received matches the calculated entitlement.
The Scale of What's Coming
$166 Billion in IEEPA Duties Across 53 Million Entries
The Protest Window Is Closing on Some Entries Now
Don't Wait for the CAPE Portal to Open
The most urgent action is not preparing for CAPE — it is identifying liquidated entries approaching the 180-day protest deadline and acting before that window closes. A complimentary 30-minute assessment with MyCustomsInfo® identifies your full IEEPA entry exposure, flags entries at protest risk, confirms your ACH registration status, and builds your Phase 1 CSV dataset before the ACE portal goes live.
Book Your Complimentary AssessmentTypically available within 1 business day · [email protected] · +1 (312) 728-4277