IEEPA Refunds Are Now Live: How to Prepare for CAPE Filing and Avoid Delays
U.S. Customs and Border Protection (CBP) has officially launched the CAPE (Consolidated Administration and Processing of Entries) portal, allowing importers to begin filing claims for IEEPA duty refunds through the ACE system.
While this marks a major step forward for the trade community, filing through CAPE is not simply a submission—it requires careful preparation. Importers who take the time to review eligibility, confirm system access, and align internally will be best positioned to avoid delays and maximize refund opportunities.
Why Preparation Matters Now
Unlike traditional refund processes, CAPE is designed to handle a high volume of claims in a consolidated format. However, refunds are not issued automatically, they must be initiated through a CAPE Declaration filed by the importer of record or their licensed customs broker.
Additionally, once a declaration is submitted and accepted, it cannot be amended. This makes upfront accuracy and coordination critical.
Understanding Phase 1 Eligibility
CBP has implemented CAPE in phases, with Phase 1 currently live.
Entries generally eligible include:
- Certain unliquidated entries
- Entries liquidated within the past ~80 days
- Entries that are suspended, extended, or under review
These entries fall within CBP’s voluntary reliquidation window, allowing adjustments to be made and refunds to be issued where applicable.
Not included in Phase 1:
- Entries with final liquidation status
- Reconciliation (Entry Type 09) entries
- Entries tied to drawback claims
- Entries under an open protest
- Certain AD/CVD entries pending liquidation instructions
CBP has indicated that additional phases will expand eligibility, though timelines have not yet been confirmed.
Radius International’s CAPE Readiness Checklist
Before submitting a CAPE Declaration, importers should take the following steps to ensure a smooth filing process:
1. Confirm ACE Portal Access
Verify that your ACE Portal account is active and that the appropriate Importer account permissions are in place. Without proper access, filings cannot be completed.
2. Validate ACH Refund Banking Information
Refunds will be issued electronically via ACH. If banking information is missing or outdated, refunds may be delayed indefinitely.
It is important to note that paying duties via ACH does not automatically qualify an importer to receive refunds—these settings must be configured separately in ACE.
3. Identify Eligible Entries
Work with your internal team or broker to determine which entries qualify under Phase 1. Filing ineligible entries may result in rejection or delays.
4. Coordinate with Your Customs Broker
Only the importer of record or the broker who filed the entries is authorized to submit CAPE Declarations. Early coordination helps ensure alignment and accuracy.
5. Review Filing Limitations
- Each declaration can include up to 9,999 entries
- Duplicate entries will be rejected
- Declarations cannot be amended after submission
- Partial acceptance may occur if some entries fail validation
What to Expect After Filing
Once a CAPE Declaration is submitted and accepted:
- CBP will validate and process the entries
- IEEPA duties will be removed and recalculated
- Entries will be liquidated or reliquidated
- Refunds, including applicable interest, will be issued via ACH
CBP has indicated a general processing timeline of 60 to 90 days, although additional compliance review may extend this timeframe.
Looking Ahead: Preparing for Future Phases
While Phase 1 does not cover all entries, additional phases are expected to expand eligibility. Importers with currently excluded entries should begin organizing documentation and evaluating potential strategies, including coordination with customs counsel where appropriate.
Early preparation will be key as CBP continues to scale the CAPE process.
How Radius International Can Support Your Team
As regulatory updates continue to evolve, having the right partner can make all the difference.
Radius International is actively supporting clients with:
- Reviewing entry eligibility for CAPE filings
- Coordinating with licensed customs brokers
- Ensuring ACE Portal readiness
- Providing guidance on compliance and documentation
Our goal is to help clients navigate the CAPE process efficiently while minimizing risk and delays.
Stay Ahead of the Process
The launch of CAPE represents a significant opportunity for importers—but success will depend on preparation, accuracy, and timing.
If you have questions about your eligibility or need assistance preparing for CAPE filing, contact Radius International today.
