CBP's CAPE System Goes Live in Weeks: Your IEEPA Refund Prep Checklist

CBP is racing to launch a brand-new refund system called CAPE — and it's your only path to recovering IEEPA duties. But one in five importers still can't receive electronic refunds, Phase 1 won't cover every entry, and your claim won't file itself. Here's exactly what you need to do before the portal opens.

As of March 30, 2026, CBP's four-part CAPE system sits between 60% and 85% complete. The target: mid-April launch. The stakes: $166 billion in IEEPA tariff refunds across 53 million entries filed by more than 330,000 importers. And here's the number that should worry you — 22% of importers who paid IEEPA duties still haven't set up electronic refund enrollment in ACE. If that's you, CBP literally cannot send you money.

The Supreme Court's February 20 decision in Learning Resources, Inc. v. Trump made it clear: IEEPA was never meant to authorize tariffs. The Court of International Trade ordered CBP to refund what importers paid. CBP responded that doing this entry-by-entry would take 4.4 million staff hours — so they're building CAPE instead. Think of it as a purpose-built refund machine inside ACE that strips IEEPA codes, recalculates duties, and pushes money to your bank account.

But machines need inputs. And right now, too many importers aren't ready to provide them.

What CAPE Actually Is (And Why It Matters)

CAPE — Consolidated Administration and Processing of Entries — is a new module inside the Automated Commercial Environment (ACE) platform, designed specifically to handle IEEPA refund claims at scale. It's not an upgrade to an existing process. It's entirely new infrastructure that CBP is building under court order.

Brandon Lord, CBP's Executive Director of Trade Programs, laid out the architecture in a March 31 filing with the CIT. CAPE has four integrated components, each at a different stage of completion:

The Mass Processing component — the engine that actually recalculates what you owe minus IEEPA duties — is the least finished piece at 60%. That's the component doing the heavy lifting across millions of entry summaries, so the lower completion rate makes sense. But it also means mid-April is ambitious.

The 45-Day Clock: How Refunds Will Actually Flow

Once CAPE goes live, here's the process CBP has outlined:

1. You submit a CAPE Declaration through the ACE portal. This is a CSV file listing every entry summary for which you're requesting a refund.
2. CAPE validates your submission — checking format, completeness, and eligibility against ACE records.
3. Mass Processing strips IEEPA HTS numbers from validated entries and recalculates duties as if those tariffs never existed.
4. Review & Liquidation sets a reliquidation date, updates the entry summary to reflect new total duties, and calculates interest owed to you.
5. The Refund component consolidates what you're owed by liquidation date and Importer of Record (IOR) — or designated party via CBP Form 4811 — and pushes an ACH payment to your registered bank account.

CBP says this entire cycle will take approximately 45 days from declaration acceptance to refund. That's the target. Whether it holds at scale across millions of entries is another question entirely.

Phase 1: What's Covered and What's Not

This is where things get tactical. CAPE isn't launching as a one-size-fits-all solution. Phase 1 will handle roughly 63% of entries on which IEEPA duties were paid or deposited. That's a majority — but it means more than a third of affected entries need a different path.

Entries Eligible for Phase 1

• Unliquidated entries — the biggest category, covering 20+ million entries still open in ACE
• Entries within the 90-day voluntary reliquidation period under 19 U.S.C. § 1501
• Entries with liquidation status marked "suspended," "extended," or "under review"
• Warehouse and warehouse withdrawal entries
• Entries liquidated within the preceding 80 days — CBP targets completing these by the 90th day to stay within the voluntary reliquidation window

Entries NOT Eligible for Phase 1

Here's the list that could trip you up:

• Entries flagged for reconciliation, including Entry Type 09
• Entries designated on drawback claims — if you've already claimed drawback, CAPE won't touch these initially
• Entries with open protests — ironically, if you already protested, you may wait longer
• Entries not filed in ACE or entries lacking liquidation status in the system
• AD/CVD entries where the Commerce Department has issued liquidation instructions pending liquidation under 19 U.S.C. § 1504(d)

If your entries fall into these excluded categories, you're looking at Phase 2 or beyond. CBP has outlined future functionality including reconciliation and drawback claim processing, complex interest calculations, final liquidation processing, and non-ABI entry handling — but no timeline has been set.

The Enrollment Problem: Why 22% of Importers Are Locked Out

As of March 26, 2026, 26,664 importers of record have completed ACH electronic refund enrollment — representing 78% of all IEEPA tariff entries by value, roughly $120 billion. That sounds decent until you flip it: 22% of importers who paid IEEPA duties cannot currently receive a refund because they haven't enrolled.

Here's why this matters more than you think. CBP stopped issuing paper refund checks on February 6, 2026. The Electronic Refunds Interim Final Rule, published January 2, 2026, made ACH the only game in town, with limited exceptions. If you're not enrolled when CAPE processes your declaration, CBP will place your refund in reject status. Your money sits in limbo until you update your banking information and notify CBP.

The enrollment itself isn't complicated — you do it through the ACE Secure Data Portal — but if you're one of the 330,000+ affected importers and you haven't done it yet, you're running out of runway.

The CIT's Expanding Order: Finally Liquidated Entries Get a Lifeline

One of the biggest open questions in the IEEPA refund saga has been: what happens to entries that are already finally liquidated — past the 180-day protest window? These importers paid IEEPA duties, their entries closed, and the clock ran out.

On March 27, 2026, Judge Eaton at the CIT answered that question with an amended order: "any liquidated entries for which liquidation is final shall be reliquidated without regard to the IEEPA duties." That's a significant expansion. It means importers won't be time-barred from recovering refunds just because CBP took too long to build a refund system.

But there's a catch. The Administration has signaled it will aggressively contest refunds and process them only upon a "final and unappealable decision." With the government likely to appeal aspects of the CIT's orders, finally liquidated entries may be the last to see actual money. Don't count on quick resolution here.

What Tariffs Are Actually Covered

Not every tariff imposed since 2025 is an IEEPA tariff. Here's what's in scope for refunds:

• "Fentanyl" tariffs on imports from China, Canada, and Mexico — imposed starting February 4, 2025
• "Reciprocal" tariffs — the broader set of country-specific tariffs imposed starting April 2, 2025
• IEEPA tariffs on Brazil and India — added by the CIT's expanded order

All IEEPA duties paid from these effective dates through February 24, 2026 (when CBP stopped collecting them post-Supreme Court ruling) are eligible. Section 301 tariffs, Section 232 tariffs, and AD/CVD duties are separate authorities — they're not affected by the IEEPA ruling and won't be refunded through CAPE.

Your Pre-Launch Action Checklist

CAPE's portal could open within two weeks. Here's what to do now — not later:

1. Verify ACH enrollment in ACE — Log into the ACE Secure Data Portal and confirm your banking information is current. If you use a customs broker, confirm they've updated your IOR payment profile. This is the single most important step, and the one most likely to delay your refund.

2. Compile your entry data in CSV format — CAPE's Claim Portal requires CSV uploads. Pull every entry summary where IEEPA duties were assessed. You need accurate entry numbers, HTS classifications, and duty amounts paid. If your data lives in spreadsheets, customs management software, or broker reports in different formats, start consolidating now.

3. Identify which entries qualify for Phase 1 — Cross-reference your entries against the eligible categories above. Flag anything in reconciliation, on drawback claims, with open protests, or subject to AD/CVD suspension. These need separate tracking and a different recovery strategy.

4. File protests for liquidated entries — If you have entries that are liquidated but still within the 180-day protest window, file protests now under 19 U.S.C. § 1514. Yes, the CIT's March 27 order covers finally liquidated entries, but that order could be appealed. Protests preserve your rights as a backup.

5. Talk to your customs broker and trade counsel — Especially if you have entries excluded from Phase 1 or entries that are finally liquidated. The legal landscape is still shifting, and CIT litigation may be necessary for some claims.

What's Coming Next

The next few weeks will be critical. Watch for these developments:

• Mid-April 2026: Expected CAPE Phase 1 launch. CBP has committed to this timeline in court filings, but the 60% completion rate on Mass Processing leaves room for delay.
• Government appeals: The Administration has signaled it won't quietly process $166 billion in refunds. Expect legal challenges to the CIT's expanded orders, particularly the March 27 amendment covering finally liquidated entries.
• Phase 2 timeline: CBP hasn't committed to dates for reconciliation entries, drawback claims, or non-ACE entries. If your entries fall here, plan for months, not weeks.
• Interest calculations: CBP owes interest on refunds under 19 U.S.C. § 1505. The CAPE system will calculate this automatically, but the methodology hasn't been publicly detailed yet.

The Bottom Line

The IEEPA refund process is unprecedented in scale — 53 million entries, $166 billion, a brand-new system built under court order in weeks. CBP is moving faster than anyone expected, but "fast for government" still means you need to be proactive. Refunds are not automatic. If you don't submit a CAPE Declaration, you don't get paid. If you haven't enrolled in ACH, your refund gets rejected. If your entries aren't in Phase 1, you need a Plan B.

Tools like TariffLens can help you quickly identify which of your entries carried IEEPA duties and which HTS codes are affected — saving hours of manual cross-referencing as you prepare your CSV declarations.

The money is coming. Make sure you're ready to receive it.

This article is for informational purposes only and does not constitute legal, tax, or customs advice. Consult a licensed customs broker or trade attorney for guidance specific to your situation.