Q&A: How to Submit Your IEEPA Refund Claim as CAPE Portal Launches April 20, 2026

The US Customs and Border Protection (CBP) has announced its long-awaited functionality allowing importers of record (IORs) or customs brokers (CBs) filing the Consolidated Administration and Processing of Entries (CAPE) to streamline the submission and processing of refund requests for duties imposed under the International Emergency Economic Powers Act (IEEPA) that were found unconstitutional by the U.S. Supreme Court (as reported on in our prior alert). It will become available on April 20, 2026, at 8 am ET.

What is CAPE?

CAPE is designed to consolidate refunds of IEEPA duties, including interest, rather than processing refunds on an entry-by-entry basis, and to streamline the submission process through the Automated Commercial Environment (ACE). CAPE will be deployed in phases, and the first phase will be limited to certain unliquidated entries and certain entries within 80 days of liquidation.

Who is CAPE Available to?

CAPE will be available to IORs who have an established ACE Secure Data Portal account and use the ACE Portal account to provide CBP with bank account information.

What is the CAPE Refund Approval Process?

In order to claim the refund, a CAPE declaration that consists of up to 9,999 entries for which refunds of IEEPA duties are being requested will need to be filed through the IORs’ web-based ACE account using a Comma-Separated Values (CSV) file.

Once a CAPE Declaration is validated and accepted, ACE will update the appropriate entry summary lines by removing the IEEPA duties. Following the CBP review, such entries will be liquidated. In most cases, IEEPA refunds are expected to be issued within 60 –90 days following acceptance of the CAPE Declaration.

We are Here to Help

Hinshaw’s international corporate and transactional attorneys can assist clients with a structured approach to obtaining IEEPA tariff refunds. Please note, however, that only the IOR or the licensed CBs who filed the entries can file a CAPE Declaration.

We will continue to closely monitor further developments and deployment of the next CAPE phases. Please contact Hinshaw’s international corporate and transactional attorneys for inquiries: Megan Mathias, Justyna Regan, or your Hinshaw attorney for more information.