U.S. Customs and Border Protection (CBP) recently shared updates regarding the refund process for duties collected under the International Emergency Economic Powers Act (IEEPA). In a document filing with the Court of International Trade (CIT) on March 12, 2026, the agency revealed it’s building a new module within the Automated Commercial Environment (ACE) to handle returns.
CAPE: The new CBP refund system
To manage the unprecedented volume of tariff returns, CBP designed the Consolidated Administration and Processing of Entries (CAPE). This module lives within the existing ACE framework and introduces new capabilities explicitly built for duty refunds.
The core functionality is in development and CBP plans to implement the module in phases. As currently presented to the CIT, the CAPE system relies on four integrated structural pillars.
The four pillars of CAPE
- Claim portal: This web-based interface will serve as the starting point for all refund requests. Importers and brokers will submit their IEEPA refund requests (“CAPE Declarations”) directly through this portal.
- Mass processing: Instead of handling requests one by one, the system will allow filers to upload a Comma-Separated Values (CSV) file. This file is to contain all the entry summaries eligible for refunds, allowing ACE to process massive volumes of entries in bulk.
- Review and liquidation: ACE will systematically remove the specific IEEPA Chapter 99 line items from the entries. The system will then recalculate the duties owed and route the entries for liquidation or reliquidation after a designated review period.
- Refund processing: The final step is to push the finalized entries through a CAPE-specific refund process. ACE Collections will consolidate the payments by importer and date, setting them up for electronic distribution.
How the CAPE workflow will operate
The CAPE workflow will function through a highly automated series of validations, recalculations, and refund steps. Understanding this workflow can help importers anticipate potential delays and structure their data correctly from the start.
- File validations
The process begins when a CAPE Declaration is uploaded into the system. ACE instantly performs a series of file-level validations. These checks ensure the submission meets all technical and authorization requirements. The system verifies that all necessary information is present and formatted perfectly. It also confirms that the filer is either the Importer of Record (IOR) or an authorized customs broker. Finally, it checks that the CSV file itself is clean and uncorrupted. If the file fails any of these initial checks, ACE rejects the entire submission and highlights the errors to be fixed. - Entry validations
Once the file passes the first test, the system evaluates every entry listed in the CSV document. It confirms that the entry actually exists within the ACE database, and it verifies that at least one IEEPA Chapter 99 Harmonized Tariff Schedule (HTS) number was declared on that specific entry. If an individual entry fails this validation, ACE removes it from the batch. However, the rest of the entries will continue moving forward. Rejected entries can be corrected and submitted in a separate, future CAPE Declaration. - Mass processing
Once validated, the entries are processed. CAPE performs automated recalculations, strips away the IEEPA Chapter 99 tariff lines and runs standard duty validations again. It recalculates the final duty amounts exactly as if the IEEPA tariffs had never been declared. This batch processing allows CBP to handle large volumes of entry recalculations simultaneously. - Review and liquidation or reliquidation
Once the processing is completed, the entries are scheduled for liquidation or reliquidation. This does not happen instantly. ACE sets a specified number of days after acceptance before the liquidation occurs, giving CBP officers time to conduct internal reviews if necessary. During this cycle, the system will update the final duty totals and automatically calculate any interest owed to the importer. CBP will process these liquidation actions strictly from Monday through Thursday each week. - Issuing the refund
The final step is the actual payment. Once entries liquidate or reliquidate, they move into the ACE Collections module. The system groups refunds based on the liquidation date and the Importer of Record number. If the importer designated a different recipient (such as a customs broker) using a CBP Form 4811, the system routes the funds accordingly. CBP issues these payments electronically.
Phased rollout and early exclusions
Importers should not expect every single entry to process on day one. CBP anticipates a phased implementation for the CAPE system. The initial phase focuses entirely on standard, uncomplicated entries.
By focusing on simple entries first, CBP can return the largest volume of money to the market as quickly as possible. Entries that involve complex trade scenarios will likely need to wait for later phases. Early exclusions from the CAPE system include entries subject to Antidumping or Countervailing Duties (AD/CVD). CBP will also exclude entries with liquidation statuses marked as suspended, extended, or under review. Furthermore, warehouse withdrawals and entries associated with drawback claims will not qualify for the initial processing phase.
Immediate planning considerations for importers
While CBP actively builds the CAPE infrastructure, the system remains under development. Claims can’t be submitted yet, but importers can take steps to prepare.
1. Confirm ACE Portal access: CAPE requires active portal users to identify impacted entries, pull necessary reports, and submit the final CAPE Declarations. If your login credentials expired, fix them today.
2. Dig into trade data: Use the reporting tools available in ACE or your customs broker’s analytics platforms to identify and flag every entry impacted by IEEPA duties. Segment this data clearly. Separate standard, simple entries from complex ones (like AD/CVD or entries associated with drawback entries). This segmentation allows you to file your clean, standard entries the moment phase one opens.
3.Verify financial routing information: CBP issues refunds electronically based on information provided in ACE. Confirm that your Automated Clearing House (ACH) information is accurate. If you use a customs broker to receive refunds on your behalf, double-check that your CBP Form 4811 designations remain active and current.
By organizing your entry data and verifying your financial details now, you remove the friction from the upcoming refund process.