CAPE System Launch: What U.S. Importers Need to Know
CBP announces the CAPE system launch date of April 20, 2026. Here's what importers should do now to prepare for IEEPA tariff refund filings.
The U.S. Customs and Border Protection (CBP) launched the CAPE (Consolidated Administration and Processing of Entries) system on April 20, 2026. The April 2026 guidance confirmed that this is a structured ACE workflow with strict validations, not a general catch-all refund shortcut.
What is CAPE?
CAPE is a new module within the ACE (Automated Commercial Environment) Portal specifically designed to process IEEPA tariff refund declarations. It eliminates the need for paper-based filings and streamlines the refund process. As of May 26, 2026, CAPE has accepted 15.8 million entries and certified $20.6 billion in refunds to Treasury with an average 18-day turnaround for clean entries.
Source: CBP Lord Declaration filed with the Court of International Trade on May 26, 2026, summarized in our CIT show cause order analysis.
Who Should Prepare?
Any U.S. importer who paid duties under IEEPA tariffs — specifically HTS Chapter 99 subheadings 9903.01.25 through 9903.01.70 — should begin preparing now.
Steps to Take Now
- Verify your ACE Portal access — The filer must be the importer of record or the broker that filed the entry summary.
- Register ACH refund information — Refunds are electronic-only after February 6, 2026.
- Compile your entry numbers — The CAPE upload is an entry-number-only CSV.
- Check liquidation status — Phase 1 centers on unliquidated and recently liquidated entries.
Phase 1 Coverage
The initial launch covers:
- Unliquidated entries
- Entries liquidated within approximately 80 days of filing
- Certain warehouse or suspended entries may still move, but not on the standard 45-day timeline
CBP deployed Phase 2 reconciliation functionality on June 29, 2026 for eligible reconciliation-flagged entries without an Entry Type 09 on file. Its October 6 declaration confirms limited Phase 3 deployment for finally liquidated entries covered by court reliquidation orders. The first group supplied valid IOR numbers by July 30; there is no general lane for non-litigants.
Update — September 22, 2026: Limited Phase 3 Gets an October 6 Target
- CBP’s September 15 Lord Declaration, ECF No. 50 sets the planned date and plaintiff-specific eligibility; see the Phase 3 eligibility checklist.
- The September 17 CIT order, ECF No. 52 requires a report October 6 and a closed conference October 7. Continue eligible CAPE filings and preserve available protest rights.
Update — October 14, 2026: Limited Phase 3 Is Live
- CBP says Phase 3 deployed at 5:10 a.m. Eastern on October 6 for finally liquidated entries covered by CIT reliquidation orders. The first cohort supplied valid IOR numbers by July 30; later submitters await instructions. Source: ECF No. 58.
- The October 8 Freestyle World opinion certified a Rule 23(b)(2) class but did not itself order refunds or create a filing procedure for all class members. See Slip Op. 26-123.
- CBP’s next CAPE report is due October 26 at 5 p.m. Eastern, followed by a closed conference October 27 at 2 p.m. Eastern. The parties’ proposed class-case schedule is due October 22. Source: ECF No. 60.
For a complete walkthrough, read our Step-by-Step Guide or check your eligibility.