Understanding IEEPA Duty Refunds: What Importers Need to Know
- 3 days ago
- 2 min read
As the industry continues to navigate the evolving landscape of tariffs and trade enforcement, U.S. Customs and Border Protection has introduced a structured approach to refund duties collected under the International Emergency Economic Powers Act (IEEPA).
This development represents a significant opportunity for importers and brokers—but also requires careful preparation to ensure eligibility and timely processing.
A New System for Processing Refunds
CBP is implementing a new automated solution within the Automated Commercial Environment (ACE) called:
Consolidated Administration and Processing of Entries (CAPE)
Beginning April 20, 2026, importers and their authorized brokers can begin submitting refund requests through this system.
CAPE is designed to streamline what is expected to be a high volume of refund claims while maintaining compliance and accuracy across all submissions.
Who Can Request Refunds?
Only the following parties are authorized to submit a CAPE Declaration:
The Importer of Record (IOR)
The licensed customs broker who filed the original entries
Each submission must be filed through the ACE Portal, and entries can only be included once per declaration.
Key Requirements to Prepare
Before submitting any request, importers should ensure:
They have an active ACE Portal account
Their banking information is properly set up for ACH refunds
They have compiled a list of entries where IEEPA duties were paid
Important: Refunds will not be issued until ACH information is correctly established in the ACE Portal.
How the Refund Process Works
CBP will roll out refunds in phases.
Phase 1 includes:
Certain unliquidated entries
Certain liquidated entries within 80 days of liquidation
Once a CAPE Declaration is accepted:
A claim number is issued
Entries are validated
Processing begins
Timeline for Receiving Refunds
Importers can expect:
👉 60–90 days after acceptance of the CAPE Declaration
This timeline may vary depending on:
compliance reviews
entry status (e.g., suspended or under review)
Important Limitations to Keep in Mind
CAPE Declarations cannot be amended once accepted
Additional eligible entries must be submitted in a new declaration
Refunds are issued electronically only (ACH)
Looking Ahead: Future Phases
CBP is already evaluating additional capabilities for future phases, which may include:
Entries under reconciliation
Drawback claims
Entries with open protests
Entries subject to AD/CVD measures
Further updates are expected as the system evolves.
Final Thoughts
The introduction of CAPE marks a major step toward efficiently processing IEEPA-related refunds. However, success will depend on preparation, accurate data, and timely submission.
For importers and brokers, now is the time to:
verify ACE access
update ACH information
organize historical entry data
Taking these steps early will ensure you are ready to take full advantage of the refund process as it becomes available.
Attached is the full CBP trade bulletin:
