The U.S. Customs and Border Protection (“CBP”) website provided significant updates on April 10, 2026, regarding Consolidated Administrative and Processing of Entries (“CAPE”) Phase 1 for refunds on International Emergency Economic Powers (“IEEPA”) duties. For a summary of the CAPE system, please see our prior post here: International Trade Lawyer | CBP Tariff Refund Process Update 2026.

CBP announced Phase 1 of CAPE will launch April 20, 2026.

Eligible Phase 1 IEEPA entries include:

  • Unliquidated entries;
  • Entries liquidated within the preceding 80 days; and
  • Entries with liquidation status of suspended, extended, or under review.

IEEPA Tariff Refund Update 2026 - Chan Vitanza LLP

While CBP has not further specified which entries will be included in Phase 1, CBP did not include the following entries in Phase 1 and is considering subsequent phases for these entries:

  • Entries that have been flagged for reconciliation, as well as 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;
  • Entries subject to Antidumping/Countervailing Duties (“AD/CVD”), for which the Department of Commerce (“DOC”) has issued liquidation instructions, that are pending liquidation in accordance with 19 U.S.C. § 1504(d);
  • Entries liquidated more than 80 days but not more than 180 days prior; and
  • Entries for which liquidation is final.

CBP provided the following summarized instructions for requesting IEEPA refunds:

  • Importers of Record (“IORs”) and authorized Customs brokers (“brokers”) have an ACE Secure Data Portal account;
  • Recipients of refunds use ACE to provide CBP with the Recipients’ bank account information; and
  • IORs and brokers submit CAPE Declarations on ACE.

CAPE Declarations must be filed to comply with the CAPE system:

  • A CAPE Declarations template will be available through the “Upload” button on CAPE;
  • Each CAPE Declaration has an entry limit of 9,999;
  • If you have more than 9,999 entries, you may file more CAPE Declarations;
  • If you learn you have additional entries not on your original CAPE Declaration, you may file another CAPE Declaration;
  • Once CBP accepts the filed CAPE Declaration; you cannot amend your CAPE Declaration;
  • Each entry can only be filed on one CAPE Declaration;
  • If the CAPE Declaration is accepted, you will receive a CAPE claim number;
  • Any entries which are not accepted, will be removed from the CAPE Declaration; and
  • IORs and brokers can view which entries were accepted or rejected and, if rejected, the reason.

IEEPA refunds will be issued electronically through CAPE:

  • Refunds will be consolidated by IORs or brokers;
  • Refunds will be paid through Automated Clearing House (ACH);
  • You must have your current ACH account information in order to receive your refund; and
  • Refunds will generally be issued within 60-90 days after acceptance of a CAPE Declaration.

Court of International Trade and CAPE

On April 14, 2026, the Court of International Trade (“CIT”) issued an order confirming CBP is on track to launch CAPE Phase 1 on April 20, 2026, for IEEPA duties with interest. The Court directed CBP to provide a progress report on Phase 1’s functioning by April 28, 2026.

Next Steps for Importers

These steps will help ensure importers are prepared to submit their CAPE Declarations as soon as the CAPE System launches:

  • Have an ACE Portal account;
  • Make sure to have an “Importer” sub-account in the ACE Portal;
  • Enter your bank account information to your ACE Portal account; and
  • Compile lists of your entries for which IEEPA duties were paid.

CBP expects valid IEEPA refunds to be issued within 60-90 days following acceptance of the CAPE Declaration. Preparing now will position importers to submit CAPE Declarations with the CAPE Phase 1 launch.

If you know you have entries that are likely to be part of Phase 1, do not hesitate to contact us for assistance with submission; for all other entries, we are available to help navigate the process, including identifying the applicable entry categories and the appropriate paths to be followed.