CBP’s IEEPA Refund Portal Opens April 20, 2026: What Importers Need to Know

U.S. Customs and Border Protection (CBP) has officially confirmed that the IEEPA duty refund process will begin on April 20, 2026, with the launch of a new system within the Automated Commercial Environment (ACE) known as CAPE (Consolidated Administration and Processing of Entries).

This development follows the Supreme Court’s February 20 ruling that invalidated IEEPA tariffs, creating a significant opportunity for importers to recover previously paid duties. However, the refund process is not automatic and requires action from importers of record or their licensed customs brokers.

What Is CAPE and How Does It Work?

CAPE is CBP’s centralized solution designed to efficiently process the large volume of IEEPA refund claims. Instead of handling entries individually, CAPE allows filers to submit a CAPE Declaration, which is a structured file (CSV format) listing all eligible entry summaries.

Once submitted, the system will:

  • Validate the entries included in the declaration
  • Confirm the presence of IEEPA Chapter 99 tariff provisions
  • Remove those provisions from the entries
  • Recalculate the duties owed without IEEPA tariffs
  • Process liquidation or reliquidation of entries
  • Issue refunds, including applicable interest, via ACH

This streamlined approach is intended to improve processing efficiency while maintaining compliance oversight.

Phase 1 Scope and Limitations

CBP has implemented a phased rollout for the refund process.

Entries Included in Phase 1:

  • Certain unliquidated entries
  • Entries liquidated within the previous 80 days
  • Entries with statuses such as suspended, extended, or under review

These entries may be processed for refunds within the 90-day voluntary reliquidation window under 19 U.S.C. § 1501.

Entries Not Included in Phase 1:

  • Entries with final liquidation status
  • Reconciliation entries (Entry Type 09)
  • Entries associated with drawback claims
  • Entries under an open protest
  • Entries not filed in ACE or lacking a liquidation status
  • Certain AD/CVD entries pending Commerce instructions

CBP has indicated that these categories may be addressed in future phases, although a timeline has not yet been provided.

Key Filing Requirements

Importers should be aware of several critical rules when preparing to file refund claims:

  • Filing is required: CBP will not issue refunds automatically
  • Authorized filers only: Claims may only be submitted by the importer of record or the licensed customs broker who filed the entries
  • Declaration limits: Each CAPE Declaration may include up to 9,999 entries
  • No amendments: Once submitted and accepted, declarations cannot be modified
  • No duplicates: Each entry can only be submitted once; duplicates will be rejected
  • Partial acceptance: If some entries fail validation, valid entries will still proceed

Refund Timeline

CBP has stated that refunds will generally be issued within 60 to 90 days following acceptance of a CAPE Declaration. However, processing times may vary if additional compliance review is required.

Critical Action Items for Importers

Before submitting any claims, importers should take the following steps:

1. Verify ACE Portal Access

Ensure your ACE Portal account is active and includes the appropriate Importer account permissions.

2. Confirm ACH Banking Information

Refunds will be issued electronically via ACH. If banking information is not properly established or up to date, refunds may be delayed indefinitely.

It is important to note that paying duties via ACH does not automatically qualify an importer to receive refunds via ACH—these are separate configurations within ACE.

Preparing for Future Phases

While Phase 1 is limited in scope, CBP has indicated that additional phases will expand eligibility to include currently excluded entries. Importers with entries outside of Phase 1 should consider consulting with customs counsel to evaluate potential protective actions, such as filing protests where appropriate.

How Radius International Can Help

Navigating regulatory changes like the IEEPA refund process can be complex, especially with phased rollouts and strict filing requirements.

Radius International is actively monitoring CBP guidance and can assist with:

  • Reviewing entry eligibility for Phase 1
  • Coordinating with licensed customs brokers
  • Preparing for CAPE Declaration submissions
  • Advising on compliance and documentation requirements

Our team is committed to ensuring clients are informed, prepared, and positioned to recover eligible duties efficiently.

Stay Informed

As CBP continues to release updates and guidance, Radius International will provide ongoing insights to help clients adapt to evolving trade regulations.

For questions regarding IEEPA refund eligibility or assistance with the CAPE filing process, contact our team today.