Frequently Asked Questions About IEEPA Tariff Refunds

CAPE (Consolidated Administration and Processing of Entries) is a new ACE workflow that CBP built to process IEEPA duty refunds electronically. In Phase 1, the system validates uploaded entry numbers, recalculates duties without IEEPA, and then consolidates eligible refunds by importer or designated 4811 party.

No. The court rulings created the basis for refunds, but importers still need the right filing path, the right entry status, and valid refund setup. CAPE helps with submission, but it does not make every refund automatic.

Importers that paid qualifying IEEPA Chapter 99 duties may have refund rights, but CAPE Phase 1 is narrower than the full universe of IEEPA entries. The cleanest Phase 1 candidates are unliquidated entries and entries liquidated within roughly 80 days, provided they also pass CBP's validation rules.

The target refund is the IEEPA duty amount that CBP removes from accepted entries, plus applicable interest. In practice, the payment can be reduced if CBP applies the refund against unpaid CBP debts. CBP reported $136.6 billion accepted for CAPE processing and about $126 billion certified and sent to Treasury as of October 2, 2026. Sent to Treasury does not mean every importer has received payment.

As of October 2, CBP reported $136.6 billion accepted for processing, about $126 billion certified and sent to Treasury, and 20,362 refunds totaling about $1.1 billion not transmitted because ACH information was missing. The October 6 declaration also confirms Phase 3 launched for a limited group of plaintiffs with court-ordered reliquidation. Treasury transmission is not proof of payment to an individual importer; verify your ACE refund record and banking details.

CIT Judge Eaton issued a show-cause order requiring CBP to address finally liquidated entries and initially ordered Commissioner Rodney Scott to appear at the June 9 hearing. The personal-appearance requirement was later withdrawn, and CBP Trade Executive Assistant Commissioner Susan Thomas testified. On July 17, the court ordered reliquidation for plaintiffs in approximately 3,700 assigned IEEPA cases. CBP deployed Phase 3 on October 6 for finally liquidated entries covered by CIT reliquidation orders; the initial group supplied valid IOR numbers by July 30. The October 8 Freestyle World class-certification ruling is procedural and does not itself order refunds or create a general CAPE filing procedure. File eligible CAPE entries, preserve protest rights, and obtain CIT advice for material finally liquidated claims.

Phase 1 primarily covers accepted unliquidated entries and accepted entries that are not more than approximately 80 days past liquidation. Some entries, such as warehouse or suspended entries, may still move through CAPE but on a slower liquidation timetable.

That entry is generally outside the current CAPE Phase 1 lane. Depending on the facts, you may need to evaluate a protest, litigation, or a later administrative path instead of assuming CAPE can still process it.

CBP's April 13 guidance specifically says an AD/CVD entry summary in pending liquidation status will not be accepted on a CAPE declaration. That does not make every AD/CVD-related scenario identical, but it does mean Phase 1 is not a simple path for pending-liquidation AD/CVD entries.

Open or suspended protests cause a CAPE rejection. CBP also says that if a protest was filed solely for IEEPA refund purposes and the entry is still within the 80-day CAPE window, the importer may withdraw the protest and then submit the entry through CAPE.

Entries tied to drawback are not accepted in CAPE Phase 1. CBP also instructs filers to submit CAPE for IEEPA refunds before filing a drawback claim on the same entries.

A CAPE declaration must be filed through ACE by either the importer of record or the broker that filed the underlying entry summaries. If your broker will file everything for you, you do not necessarily need your own ACE account, but you still need refund banking information set up for the proper recipient.

Yes. Refund banking is separate from normal duty payment information. Since October 10, CBP also requires email-token verification when an authorized ACE user adds or changes ACH refund details; SMS can be selected as an additional token channel. Other authorized users may enable change alerts. See CSMS #70162211 and the ACE setup guide.

Yes, but CBP's current rule is narrower than “any broker.” The submitting broker must be the broker that actually filed the entry summary on behalf of the importer of record.

CBP's September 30, 2026 IEEPA Duty Refunds FAQ identifies two methods: a licensed customs broker with a valid POA can submit updates using ABI Action Code U, or importers with an ACE Portal account and user access can update their information directly in the portal. Complete every required field accurately. Correcting Form 5106 does not establish Phase 3 eligibility or extend a protest deadline.

CBP's ACE quick reference guide shows that the Upload File button stays disabled until the filer checks the acknowledgement box on the CAPE upload screen. If the file still will not upload after that, verify that you saved the template as a CSV and that the file size stays under 1 MB.

File Uploads is the ACE work area for upload jobs and validation result files. Claim Status is where you review the claim-level outcome after ACE processes the declaration. In practice, you need both: File Uploads for job and formatting problems, Claim Status for accepted-versus-rejected entry results.

CBP says the CAPE upload should be a CSV containing entry numbers only. Use the CAPE template inside ACE, keep the file to 9,999 entries or fewer, and do not add extra columns unless the official template requires them.

CBP's operational guidance focuses on correcting rejected entries by fixing the issue and resubmitting those entries on a separate CAPE declaration. In practice, that means you should treat the initial upload as a controlled filing rather than something you can casually revise later.

ACE validates duplicates. A duplicate can cause the specific entry to be rejected, and duplicate usage across declarations is also a problem. Clean your file before submission.

That status usually means ACE found a file-level or entry-format problem before it reached deeper claim review. Examples in CBP's ACE quick reference guide include entry numbers that are not 11 characters long, duplicate entry numbers, or filer-code mismatches.

That status usually means ACE could read the file but rejected one or more entries during deeper validation. CBP's examples include an entry not found in ACE or an importer-of-record mismatch.

It means ACE accepted at least part of the declaration while still rejecting or flagging some entries. Do not assume the claim is clean. Open Claim Status, download the claim details, and isolate the rejected entries before you resubmit anything.

CBP's ACE quick reference guide draws that line directly. If the issue is a file upload error, correct it and reupload the full file. If the issue appears in claim-level results, correct only the rejected entries and submit those entries on a new CAPE declaration.

No. CBP's Federal Register Doc. 2026-20228, 91 FR 63299, is a 30-day notice requesting comments on the CAPE information collection. November 4, 2026 is the public-comment deadline. The notice reiterates account, CSV and ACH requirements; it does not activate Phase 3 or replace a liquidation-based protest deadline.

No. CBP's IEEPA Duty Refunds FAQ B10 (April 15, 2026) states directly: "There are no new recordkeeping requirements for the CAPE Declaration." You should keep documentation of the entries you submitted and the validation/claim-status output for your own audit trail, but your existing customs recordkeeping obligations under 19 CFR Part 163 are not changed by CAPE.

Before submitting a CAPE declaration, you must certify that all listed entries are eligible for refund and that you have not filed duplicate claims. This is a legally binding statement.

No. CBP's April 13 guidance says filers are prohibited from initiating an IEEPA duty refund request by PSC. If you still need to file a PSC for another issue, do that before submitting the CAPE declaration.

For standard unliquidated entries, CBP says valid refunds will generally be issued within 60 to 90 days after CAPE acceptance. In practice, CBP's July 1, 2026 Lord Declaration confirms an average 18-day turnaround (~14 days for electronics/consumer goods) once entries clear validation — significantly faster than the published window for clean Phase 1 entries. Suspended, under-review, or atypical entries can still take longer.

The October 8 CIT order says direct importers who suspect CBP made a refund-calculation error should contact CBP through their assigned Center of Excellence and Expertise. Keep the claim and entry details available, and consult your broker or trade counsel if the issue affects multiple entries or a deadline. Source: Freestyle World ECF No. 60.

CBP refunds generally move electronically via ACH to the importer or designated Form 4811 party with valid banking information on file in ACE, subject to limited exceptions. CBP reported 20,362 refunds totaling about $1.1 billion not transmitted for missing ACH information as of October 2. Verify the refund recipient’s ACE banking record; changes now require email-token verification under CSMS #70162211.

CBP consolidates CAPE refunds by importer or 4811 recipient and liquidation date, so one payment can cover entries from multiple CAPE declarations. CBP also offsets unpaid debts before releasing the refund. As of May 20, 2026, CBP confirmed entry-by-entry netting of unpaid IEEPA bills against refunds.

For many importers, yes, because a timely protest preserves an additional legal path. But you also need to understand the interaction with CAPE: an open or suspended protest blocks CAPE entry acceptance until it is resolved or withdrawn.

A Court of International Trade action may be necessary for material finally liquidated claims without an administrative protest path. The October 8 Freestyle World opinion certified a Rule 23(b)(2) class of importers who paid duties under the challenged IEEPA tariff orders from February 1, 2025 through February 19, 2026, excluding entities that separately sued for recovery. Certification does not itself order refunds or create a filing process. Ask trade counsel to assess class scope, other remedies, and deadlines before relying on coverage.

No. CAPE simplifies submission but does not eliminate entry-level validation, payment holds, or legal questions outside each active lane. CBP reported 6.2 million entries failed entry-level validation and 20,362 refunds totaling about $1.1 billion were held for missing ACH information as of October 2. A court-certified class also is not itself a refund order. Use the appropriate CAPE path, preserve protest rights where available, and obtain case-specific advice for other entries.

No. CAPE Portal Guide is an informational resource. We are not a law firm, customs broker, or government agency. We provide educational content and connect importers with vetted trade law professionals.

No. We provide general guidance based on publicly available CBP information. Refund eligibility depends on your specific circumstances. We recommend consulting with a qualified trade law attorney for advice specific to your situation.