How to File for Your IEEPA Tariff Refund via CAPE

Follow these 7 steps to claim your refund through the CBP CAPE system.

Understand IEEPA Tariff Refunds

On February 20, 2026, the U.S. Supreme Court ruled 6-3 in Learning Resources, Inc. v. Trump that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) exceeded Presidential authority. As a result, an Executive Order was issued terminating all IEEPA tariffs, and the Court of International Trade (CIT) has directed CBP to refund all IEEPA-related duties collected.

Which Tariffs Are Affected?

  • IEEPA tariffs on imports from Canada (EO 14193, Feb 2025)
  • IEEPA tariffs on imports from China (EO 14195, Feb 2025)
  • IEEPA tariffs on imports from Mexico (EO 14194, Feb 2025)
  • IEEPA tariffs on imports of Venezuelan oil (EO, Mar 2025)
  • All corresponding IEEPA Chapter 99 duties (HTS subheadings 9903.01.25 through 9903.01.70)

What Cannot Be Refunded via CAPE?

  • Regular MFN duties, Section 301, Section 232, or AD/CVD duties
  • Entries with pending protests, drawback claims, or reconciliation

Protect Your Refund Rights

Trade law experts strongly advise importers to not rely solely on CAPE. You should also:

  • File timely protests — Protest liquidations within 180 days as a backup to CAPE
  • Consider CIT litigation — Filing suit at the Court of International Trade may be the only way to recover refunds on finally liquidated entries (beyond the protest window)

Consult with a qualified trade law attorney to protect your rights.

Check Your Eligibility

Phase 1 of the CAPE system covers the broadest category of entries. You're likely eligible if:

  • Unliquidated entries — duties paid but entry not yet liquidated by CBP
  • Recently liquidated entries — liquidated within approximately 80 days of CAPE filing

Phase 1 Exclusions

Entries involved in AD/CVD proceedings, drawback claims, protests under 19 USC § 1514, reconciliation, or warehouse entries are excluded from Phase 1. These will be addressed in future CAPE phases.

Use our interactive eligibility checker to quickly determine your status.

Set Up Your ACE Portal Account

CAPE declarations are filed through the ACE (Automated Commercial Environment) Portal. If you don't already have access:

  1. Visit the ACE Portal at ace.cbp.dhs.gov
  2. Request an Importer account (requires EIN or SSN)
  3. Complete identity verification
  4. Wait for account activation (typically 4-6 weeks)

Already have ACE Access?

If you or your customs broker already files entries through ACE, you likely have the needed access. Confirm that your account has the "CAPE" application enabled.

Register Your ACH Refund Account

Refunds are issued exclusively via ACH direct deposit. You must register a bank account specifically for refunds:

  • CBP requires a separate ACH refund account — your existing ACH payment account for duties cannot be used
  • Register through ACE Portal → Payment Management
  • Allow 5-10 business days for account verification

Critical: Without a verified ACH refund account, CBP cannot issue your refund even if your CAPE declaration is approved.

Prepare Your Entry Data

You'll need to compile a list of qualifying entry numbers in CSV format:

CSV Format Requirements

  • One entry number per row (11-digit format)
  • Maximum 9,999 entries per CAPE declaration
  • If you have more than 9,999, submit multiple declarations
  • No duplicate entry numbers within or across declarations

How to Identify Qualifying Entries

  • Use the ACE Reports (REV-603) to identify entries with IEEPA Chapter 99 HTS codes
  • Confirm liquidation status through ACE entry summary data
  • Work with your customs broker if they filed entries on your behalf

Submit Your CAPE Declaration

Once CAPE goes live on April 20, 2026:

  1. Log into ACE Portal and navigate to the CAPE application
  2. Create a new CAPE Declaration
  3. Upload your CSV file with qualifying entry numbers
  4. The system will validate each entry number
  5. Review validation results and correct any errors
  6. Sign the compliance certification
  7. Submit the declaration

Important: Once submitted, a CAPE declaration cannot be amended or withdrawn. Double-check all entry numbers before submitting. Duplicate entries across declarations will be rejected.

Track Your Refund

After submission, monitor your refund status through ACE:

  • REV-603 Report — Shows per-entry refund status and any rejections
  • REV-613 Report — Shows overall declaration status
  • Expect 60-90 days from acceptance to ACH deposit

Common Rejection Reasons

  • Entry number not found in CBP system
  • Entry involved in exclusion category (AD/CVD, drawback, etc.)
  • Duplicate entry number already filed in another declaration
  • Entry does not have IEEPA Chapter 99 duties

Need Professional Help?

Our vetted partner trade law firms and licensed customs brokers can handle the entire process for you.

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