On April 20, 2026, U.S. Customs and Border Protection switched on the first phase of a new system that importers have been waiting on for the better part of two years: a structured, automated way to get back the duties they paid under the International Emergency Economic Powers Act (IEEPA).

The system is called CAPE—Consolidated Administration and Processing of Entries—and it represents the first real refund mechanism for IEEPA duties. Until now, those duties were a one-way payment. CAPE turns them into something importers can actually claim back.

Here’s how it works, what Phase 1 does and doesn’t cover, and what to do about it.

What CAPE is

CAPE lives inside the Automated Commercial Environment (ACE), the platform that already handles the bulk of CBP’s electronic entry processing. Rather than building a separate portal, CBP layered the refund workflow directly onto the system importers and brokers already use.

The mechanics are deliberately structured. Filers—importers of record or the brokers acting on their behalf—submit refund claims as CSV files containing the entry numbers they want refunded. CBP validates those files, assigns claim numbers, processes the entries, and returns the money by ACH direct deposit. No paper, no individual letters, no manual back-and-forth for the entries that qualify.

IEEPA duties, for context, are the tariffs imposed under emergency economic authority. They became refundable through this process, and CAPE is the channel CBP built to deliver those refunds at scale.

The five stages of a CAPE claim

Every refund moves through the same five steps:

1. Submission. The filer uploads a CSV of entry numbers. A single declaration can hold up to 9,999 entries.
2. Validation. Two checks run in sequence—first the file format itself, then each entry, to confirm IEEPA duties were actually paid on it.
3. Claim assignment. Declarations that clear validation receive a claim number, which becomes the reference for tracking the refund.
4. Review and liquidation. CBP confirms the refund amount and processes the entries.
5. Refund. Funds are deposited by ACH to the importer of record or a designated notify party.

What Phase 1 covers

Phase 1 is intentionally limited. It handles entries that are either still unliquidated or that liquidated within the past 80 days. By CBP’s own accounting, that’s roughly 63% of eligible entries—the lower-hanging, lower-complexity fruit.

The remaining 37% are deferred to future phases that CBP has not yet scheduled.

Refund timing depends on where an entry sits:

• Unliquidated or recently liquidated entries: generally 60 to 90 days after CAPE accepts the claim.
• Suspended, extended, or under-review entries: no refund until the entry liquidates, which can push the timeline out considerably.

What’s excluded from Phase 1

Several categories of entries are not eligible yet. If yours fall into any of these buckets, filing now won’t move them:

• Entries flagged for reconciliation
• Entries designated on a drawback claim
• Entries with an open protest
• Entries not filed in ACE
• Entries subject to antidumping or countervailing (AD/CVD) duties that are still pending liquidation
• Finally liquidated entries—those that liquidated more than 80 days ago

A key correction rule (April 22 guidance)

CBP issued follow-up guidance on April 22, 2026 that’s easy to miss and expensive to ignore: once an entry has been accepted into CAPE, it can no longer be corrected through a Post Summary Correction (PSC).

A few clarifications around that rule:

• A PSC filed before CAPE submission does not block the entry from being accepted.
• If CAPE rejects an unliquidated entry, you can still correct it with a PSC before resubmitting.
• The practical implication: identify and fix any errors before you submit, not after. Acceptance locks the entry.

What importers should do now

Even with future phases undefined, there’s a clear set of preparatory moves:

• Confirm ACE Portal access and set up an ACH refund account. Without a destination for the funds, an approved claim has nowhere to go.
• Separate Phase 1-eligible entries from the rest. Submitting future-phase entries accomplishes nothing; sort them first.
• Audit your entry data for accuracy. Validation is unforgiving, so catch errors before they trigger a rejection.
• Keep filing protests on entries approaching their deadline. CAPE does not pause the protest clock.
• Engage trade advisory support if your volume or AD/CVD exposure makes the process complex.

The open questions

CAPE is live, but it’s clearly a first release. Several things remain unsettled:

• System load. ACE was already under strain, and CAPE adds roughly 53 million entries from more than 330,000 importers into the queue. Slowdowns are a real possibility.
• AD/CVD entries. About 166,000 entries subject to antidumping or countervailing duties still need a manual resolution process that CBP hasn’t finalized.
• Validation and rejection protocols. How CBP reviews entries, handles discrepancies, and manages rejections at scale is not yet fully documented.
• Future phases. The timing and procedures for the remaining 37% of entries haven’t been announced.

What’s next

CBP indicated its next CAPE progress update would come on April 28, 2026. Importers should watch for changes to validation rules and phase timing, and adjust their filing approach as the details firm up. For now, the entries that qualify under Phase 1 are the ones worth preparing—cleanly, and before the queue gets longer.