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. The Court of International Trade later directed CBP to liquidate or reliquidate eligible entries without IEEPA duties, and CBP responded by building CAPE inside ACE as the operational refund tool.

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 CAPE Actually Does

  • Accepts a CAPE declaration through ACE and assigns a CAPE claim number after validation
  • Removes applicable IEEPA Chapter 99 lines from accepted entries and recalculates duties as if IEEPA had never applied
  • Routes the entry for liquidation or reliquidation before Treasury issues the refund
  • Consolidates refunds by importer of record or designated CBP Form 4811 party and liquidation date

CAPE Is a Filing Path, Not a Guarantee

CAPE makes submission easier, but it does not remove substantive review. Before you file, confirm your data, refund recipient, and legal strategy:

  • Regular duties stay in place — CAPE only removes qualifying IEEPA duties, not normal duty, Section 301, Section 232, or unrelated charges
  • Debts can reduce the payout — CBP checks for unpaid bills before issuing a refund
  • PSC is not the refund tool — CBP says filers cannot request an IEEPA refund by Post Summary Correction
  • Surety-paid duties need separate review — CBP says do not submit entries where a surety paid IEEPA duties in whole or in part

If you also intend to use protests or litigation, align that plan before you submit the CAPE declaration.

Check Your Eligibility

Phase 1 does not cover every IEEPA refund scenario. Start with the two primary groups that CBP explicitly identified:

  • Unliquidated entries — duties were paid, but CBP has not yet liquidated the entry summary
  • Recently liquidated entries — the entry summary liquidated not more than approximately 80 days before your CAPE filing

Important: If an entry liquidated more than 80 days ago, or if liquidation is already final, CAPE Phase 1 is generally not the current filing path. That is where a protest or Court of International Trade strategy may still matter.

Entries That May Still Be Processable, But On Different Timing

  • Extended, suspended, or under-review entries stay in that status after CAPE acceptance and refund only when they later liquidate
  • Warehouse and warehouse withdrawal entries are not forced into the 45-day liquidation schedule and refund in the normal warehouse liquidation cycle

Common Phase 1 Rejection Triggers

CBP's April 13 guidance says ACE will reject or remove entries that fail validation, including:

  • Reconciliation flags or entry type 09 reconciliation entries
  • Drawback-associated entries or entry type 47 drawback claims
  • Entry type 08 USMCA duty deferral entries
  • Open or suspended protests
  • Temporary importation under bond entries
  • Pending-liquidation AD/CVD entries
  • Entries more than 80 days past liquidation
  • Entries with no IEEPA Chapter 99 line or with value incorrectly reported on the IEEPA line

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. For Phase 1, CBP says the relevant account types are Importer, Filer, and Organizational Broker.

  1. Visit the ACE Portal at ace.cbp.dhs.gov
  2. Request an Importer account (requires EIN or SSN)
  3. Complete identity verification
  4. Confirm you can see the importer record and entry summaries you intend to file

Broker Filing Rule

If a broker submits the CAPE declaration, it must be the broker that originally filed the entry summary on behalf of the importer. A different broker cannot simply upload the same entries under its own filer code.

Register Your ACH Refund Account

Refunds are issued electronically only. CBP's ACH-only refund rule took effect on February 6, 2026, so this setup is no longer optional.

  • Add valid U.S. bank information for the importer or designated 4811 notify party that should receive the refund
  • Use ACE Portal refund enrollment tools rather than assuming an existing duty payment profile is enough
  • Treat the ACH refund setup as a separate readiness item from your normal duty payment instructions
  • Complete setup before filing so accepted refunds do not stall at disbursement

Critical: CBP reported on March 27 that more than 12,300 certified refunds had already been rejected because recipients had not provided valid banking information.

Prepare Your Entry Data

CBP's current rule is narrower than many early write-ups suggested. Your CAPE upload should contain the qualifying entry numbers only.

CSV Format Requirements

  • Download the template from the CAPE tab in ACE and keep the Entry Number header row in place
  • List one complete 11-digit entry number per row in the first column, starting on row two
  • Save the file as CSV (Comma delimited) before you upload it
  • Maximum 9,999 entries per CAPE declaration
  • Keep the upload file under 1 MB so ACE does not reject it at the file level
  • No duplicate entries within or across CAPE declarations
  • Do not add entry type, dates, ports, comments, or other columns unless CBP's template specifically asks for them

How to Identify Qualifying Entries

  • Use ACE reports and entry summary data to confirm the entry contains at least one IEEPA Chapter 99 number
  • Check liquidation status before filing, especially the 80-day rule for already liquidated entries
  • Screen for open protests, drawback activity, reconciliation, surety-paid duties, and other validation blockers
  • Work with your customs broker if they originally filed the entries and will be the submitting party

Submit Your CAPE Declaration

Once CAPE goes live on April 20, 2026, the workflow is more structured than a simple upload-and-wait process:

  1. Log into ACE Portal, open the CAPE tab, and stay in the File Uploads subtab for the initial submission
  2. Download the CAPE template, prepare the entry-number-only CSV, and check the acknowledgement box so the Upload File button is enabled
  3. Upload the CSV and clear file-level validations for format, ownership, file size, and file integrity
  4. Download the Validation Result File if ACE flags Failed initial validation or Rejected by batch validation issues
  5. Review entry-level validation results for eligibility and error codes before treating the declaration as accepted
  6. Submit the declaration and receive a CAPE claim number for accepted entries

How to Read ACE Error States

  • Failed initial validation usually means a file structure or entry-format issue such as the wrong character count, duplicate entry numbers, or a filer-code mismatch
  • Rejected by batch validation usually means ACE could read the file but rejected one or more entries during deeper validation, such as an entry not found or an importer-of-record mismatch
  • Accepted with Error(s) means some entries moved forward and others did not, so you need to inspect the claim-level results before assuming the whole declaration is clean

Important: If the problem is a file upload error, correct it and reupload the full file. If the problem appears in claim results, correct only the rejected entries and resubmit those on a separate CAPE declaration. If you still need to file a PSC for some non-IEEPA issue, do that before you submit CAPE.

Track Your Refund

After acceptance, monitor both the entry status and the refund status. CAPE does not guarantee a one-line-one-refund payout.

  • REV-615 CAPE Refunds Trade Report — the new ACE report for CAPE-related refund activity
  • File Uploads — your upload history, including validation result files for job-level errors
  • Claim Status — the claim-level outcomes, where ACE labels declarations as Rejected, Accepted with Error(s), or Accepted
  • Unliquidated standard entries — generally set to liquidate 45 days from CAPE acceptance
  • Liquidated entries within 80 days — generally reliquidate the next business day
  • Refund disbursement — generally 60 to 90 days after acceptance for standard cases, with delays possible if CBP flags a compliance concern

Which File Tells You What Went Wrong?

  • Download the Validation Result File from File Uploads to see row-level upload and validation issues
  • Click the Claim Number in Claim Status to download Claim Details for each entry's status and error description
  • Use those two files together before rebuilding a declaration, especially when ACE accepts part of the submission and rejects the rest

What to Expect at Refund Time

  • Refunds are consolidated by importer of record or 4811 party and liquidation date, so multiple CAPE declarations may collapse into one payment
  • CBP checks for unpaid debts before releasing the refund, which can reduce the amount received
  • Warehouse, suspended, extended, and under-review entries can take longer because liquidation timing is not accelerated

Need Professional Help?

If your entries were filed by multiple brokers, are more than 80 days past liquidation, or involve a protest, a case-specific review can help you choose the right path before you file.

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