The short answer
Importers of record may be able to recover duties paid under tariff actions that relied on IEEPA. On February 20, 2026, the U.S. Supreme Court held that IEEPA does not authorize the President to impose tariffs. CBP now accepts qualifying refund requests through CAPE and issues validated refunds under court orders and applicable law.
A refund is not automatic for every entry. The result depends on the IEEPA duty line, who filed the entry, its liquidation status, whether the current CAPE phase can process it, and whether it passes CBP validation.
Key takeaways
CAPE is CBP’s tool for submitting and processing valid IEEPA duty refund requests in batches.
Only the importer of record or the licensed customs broker that filed the entry can submit it.
CAPE Declarations are uploaded as CSV files through the ACE Portal, not through ABI.
Each declaration can contain up to 9,999 entry numbers, and filers may submit more than one.
CBP says valid refunds are generally issued 60–90 days after acceptance, unless review or liquidation status delays payment.
An accepted declaration cannot be amended or canceled. Missing entries require a new declaration.
What are IEEPA tariff refunds?
IEEPA tariff refunds return duties collected under tariff actions that used the International Emergency Economic Powers Act as their authority when the entry qualifies for repayment. CBP removes the applicable IEEPA Chapter 99 duty line, recalculates the entry, and then liquidates or reliquidates it as appropriate.
CBP’s process includes applicable interest and consolidates approved amounts by recipient and liquidation date rather than issuing a separate payment for every entry. Refunds remain subject to normal entry accounting rules, including netting overpayments and underpayments across the entry. See CBP’s live IEEPA refund guidance.
Who can file an IEEPA refund request?
Only the importer of record or the licensed customs broker that originally filed the entries may submit a CAPE Declaration.
Importer of record
May file its own entries with the required ACE account access and refund banking information.
Filing customs broker
May file entries it originally submitted for the importer and with which it remains authorized and associated.
The refund recipient needs U.S. bank information designated for refunds in ACE. That information is separate from the ACH account used to pay CBP.
Which entries can CAPE process?
CAPE is being released in phases. The current CBP overview describes the following coverage.
| CAPE category | Current treatment |
|---|---|
| Phase 1 | Certain unliquidated entries and certain entries within the authorized reliquidation window |
| Phase 2 | Entries flagged for reconciliation where the reconciliation entry is not yet on file |
| Suspended, extended, or under-review entries | May be validated but generally keep their existing liquidation status |
| Warehouse and warehouse-withdrawal entries | May be validated, with the refund issued at liquidation |
| Entries outside available legal or liquidation authority | May require another remedy or may not currently be processable through CAPE |
CBP’s April Phase 1 materials specify most unliquidated entries and entries up to 80 days past liquidation. Because guidance is changing, confirm the current phase and rules on CBP’s live page before filing. Read the Phase 1 notice.
A practical eligibility checklist
An entry is more likely to pass initial CAPE validation when all of the following are true:
- The entry exists in ACE and has an accepted entry-summary status.
- CBP has control of the entry.
- The entry contains at least one applicable IEEPA HTS line.
- The importer account matches the importer of record on the entry.
- The filer is the importer of record or the broker that filed the entry.
- The entry has not already been included in another accepted CAPE Declaration.
- The current CAPE phase and applicable law allow CBP to process the entry.
This is a screening checklist, not a guarantee. Reconciliation, drawback, protests, warehouse status, liquidation timing, and other conditions can change the correct filing path.
How to file a CAPE Declaration
Confirm ACE access
Make sure the importer or filing broker has an active ACE Portal account and can access the CAPE tab.
Set up ACH refunds
Add the U.S. bank account that should receive customs refunds. Payment-account information does not automatically carry over.
Compile entry numbers
Identify entries containing IEEPA duties and review their liquidation and reconciliation status.
Download the CAPE template
Use the Upload button in the CAPE tab to get CBP’s current template.
Create the CSV
Enter the relevant entry numbers. A declaration can contain no more than 9,999 entries.
Upload with authority
Acknowledge filing authority and submit the file for format, account, and entry-data validation.
Review the result
Use the claim number and validation download to identify entries that need correction.
Track liquidation and payment
Follow CAPE claim status and ACE refund reporting through review and payment.
CBP’s CAPE declaration guide contains current screen-by-screen instructions and error definitions.
Current estimate
How long do IEEPA refunds take?
CBP says importers and authorized brokers should generally expect valid refunds within 60–90 days after the CAPE Declaration is accepted. That range includes CBP review and Treasury certification, but it is not a guaranteed payment date.
Payment can take longer when CBP identifies a compliance concern or when an entry is suspended, extended, under review, or waiting for liquidation.
Common CAPE errors
| Error | What to check |
|---|---|
| File rejected before validation | Confirm the file is a nonempty CSV using CBP’s current template |
| Entry-number format error | Use 11 alphanumeric characters, remove duplicates, and preserve a leading zero correctly |
| Account mismatch | Confirm the ACE importer account matches the importer of record |
| Entry not found | Verify the entry number and confirm the entry exists in ACE |
| No eligible IEEPA line | Confirm the entry contains an applicable IEEPA HTS line |
| Entry rejected by phase or status | Review liquidation, reconciliation, protest, drawback, and other entry conditions |
| Duplicate claim | Confirm the entry was not included in an earlier accepted declaration |
Once CBP accepts a declaration, it cannot be amended or canceled. If eligible entries were omitted, submit them in a new declaration.
Does CBP charge a fee?
No. CBP states that it does not charge a fee to process tariff refunds. Professional providers may charge separately for analysis, preparation, or filing assistance, but those charges do not come from CBP.
Do not send money or financial details to anyone claiming that payment is required to release a CBP refund. Use the official ACE Portal and CBP contact information.
When to get help
Complex entries need a closer review
Consider working with your customs broker or trade counsel when entries involve reconciliation, drawback, protests, suspended liquidation, warehouse withdrawals, account changes, or records spread across multiple filers.
Forge helps importers identify relevant entries, organize filing data, and submit refund requests through the appropriate customs process.
Check your entriesFrequently asked questions
What is CAPE?+
CAPE stands for Consolidated Administration and Processing of Entries. It is the tool inside the ACE Portal that CBP uses to accept and batch-process valid IEEPA duty refund requests.
Is CAPE filed through ABI?+
No. CBP requires CAPE Declarations to be uploaded through the web-based ACE Secure Data Portal. CAPE filings do not use ABI.
Can an importer file without a broker?+
Yes. The importer of record may file its own CAPE Declaration if it has the required ACE access and refund bank information. The broker that filed the entries may also file.
Can a declaration contain entries for more than one importer?+
CBP states that a broker may include entries it filed for multiple importers in one declaration. The broker still must be authorized and associated with each entry.
Does the refund include interest?+
CBP describes CAPE as consolidating valid refunds of IEEPA duties, including applicable interest. The exact calculation depends on the entry and governing customs rules.
Can I change a declaration after CBP accepts it?+
No. An accepted CAPE Declaration cannot be amended or canceled. Additional eligible entries must be submitted in a new declaration.
What if an entry is suspended or under review?+
It may still be included if the current CAPE rules allow it, but it generally keeps its existing liquidation status. A validated refund is then issued at liquidation.
What if CAPE rejects an entry?+
Download the validation result, identify the reason, and correct the entry data or filing path. A rejection can reflect formatting, account mismatch, a missing IEEPA line, duplicate filing, liquidation timing, or another status issue.
Is the 60–90 day timeline guaranteed?+
No. It is CBP’s general estimate after acceptance. Compliance review, Treasury processing, and the entry’s liquidation status can extend the timeline.
Related guides
Sources
- U.S. Supreme Court — Learning Resources, Inc. v. Trump — legal holding on IEEPA tariff authority
- CBP — IEEPA Duty Refunds — current phases, filing rules, timing, FAQs, and no-fee warning
- CBP — IEEPA Duty Refund Fact Sheet — filing authority, ACE and ACH preparation, and CSV process
- CBP — ACE Portal CAPE Declarations Guide — upload steps and validation errors
- CBP — Trade Information Notice: CAPE — Phase 1 scope and processing flow
This guide is general information, not legal or customs advice. Eligibility depends on the entry, applicable law, and current CBP guidance.
