The Future of IEEPA Refunds and the CAPE Portal

As you may know, if you have paid tariffs in the past year, you may be eligible for a tariff refund from the US Government as a result of the International Emergency Economic Powers Act (IEEPA) tariffs being deemed illegal. We know that for many importers, this refund may have seemed out of reach, with the question of who qualifies for tariff refunds under IEEPA being answer with costly litigation, but it is beginning to appear that an automated process for recovering these refunds may not be as daunting or complicated of a process as many experts expected, and the system responsible for disseminating these refunds may be coming sooner than anyone could have guessed. 

On March 31, 2026, Customs and Border Protection (CBP) released an updated status report on the advancements it has made on the Consolidated Administration and Process of Entries or CAPE system. This system will be responsible for processing and disseminating refunds related to the IEEPA tariffs, and this update has given us a look ahead at how this system will likely work, what the earliest days of its implementation will look like, and what importers need to be doing now to prepare for its release.

How We Got Here

In February of 2026, the US Supreme Court ruled that the IEEPA tariffs were unlawful. The result of that decision is that anyone who paid one of these tariffs is, through the definition of the law, entitled to a refund of that money. 

While it sounds simple in concept, the reality is that this represents billions of dollars across almost as many imports. The key challenge is that, at the time of publication, the only recourse for getting this money is to file in court for it - a costly and protracted process that has been flooding the courts since the decision was made. 

With that in mind, the question that has loomed large over the whole situation was quite simply: how is a normal person or a small business going to get a refund from CBP? We wrote a blog at the time covering most of the details of this conundrum, but the primary point was that there wasn’t a way, and that a path forward would be difficult to find.  

Fortunately, it appears that that may not be the case. In fact, much of the international trade community has been taken by surprise over the past few months by the speed at which a system for processing mass refunds is being developed, and it appears that the implementation of ‘CAPE’ could be closer to weeks rather than months. 

How CAPE Will Work - For Now

Of course, this could all easily change over the coming weeks, but as far as we know right now, CAPE is built on an ‘opt-in’ system wherein importers and brokers will need to manually request their refund by submitting the relevant documentation to CAPE via the ACE Portal. 

In broad strokes, the CAPE system is built on four key components, with entries moving through these components one at a time until the end result of a refund being dispensed. 

Claim Portal

This is the ‘CAPE’ tab in the ACE portal, where importers submit their entry summaries for review. Through that review, the system checks two boxes: 

1. Is this properly formatted, authorized, and correctly submitted? 
2. Is this entry real and valid? E.g., checking that the entry exists in ACE and confirming basic validity, including IEEPA indicators in the entry.  

Once the entries are confirmed as properly formatted and valid, CAPE moves them to component two. 

Mass Processing

During this phase, CAPE strips the IEEPA indicators from entry summaries. It then recalculates the owed duties as if the IEEPA duties were not applied. 

Notably, this also ensures that any other necessary duties and taxes are correctly applied in a very similar fashion to a typical liquidation.

Review and Liquidation/Reliquidation

Now approaching the end of the process, entries accepted by CAPE are set to liquidate or to reliquidate. Of particular importance is the fact that CBP retains the ability to conduct a manual review, and if their indications are correct, they plan to use this time effectively, ensuring that your entries are compliant and within the law.

Once set on the schedule, the entry summaries are updated with new duty totals and applicable interest and sent to the final component. 

Refund

When the refund date arrives, CAPE begins the refund process, moving through the ACE Collections module, and then distributed to bank accounts through the CBP Automated Clearing House (ACH). 

The Latest Updates

With the potential IEEPA tariff refund process explained, the latest is that on March 12, 2026, we received an update that CAPE would undergo a ‘phased roll out’, meaning it would tackle different levels of complexity bit by bit rather than attempt to handle the entirety of its backlog in one attempt. The goal is to get as much money out to as many companies and individuals as quickly as possible.  

On March 31, we received further clarity on the phased process, including what will be processed in the early stages of CAPE and what will not be. 

Phase One of CAPE’s rollout will be restricted to entries that are “unliquidated or for which the 90-day voluntary reliquidation period […] has not expired.” Notably, it will also accept entries where the liquidation status is suspended, extended, or under review, but refunds from these categories will be delayed and issued only at the end of that liquidation process, rather than as an immediate refund. 

Essentially, goods that are still in the process and uncomplicated are the first to receive a refund, and entries that are still having their ultimate fate determined will be on a longer timeline and will receive an updated liquidation as a matter of course. 

With that in mind, several types of imports will not be accepted in the first phase of CAPE, namely:

• Entries that are flagged for reconciliation
• Entries with a drawback claim
• Entries not filed in ACE or don’t yet have a liquidation status in ACE
• Entries subject to anti-dumping or countervailing duties (AD/CVD) for which liquidation instructions have been issued by Commerce and are pending liquidation 
• Entries that are currently covered by an open protest 

So, how long do CBP tariff refunds take in CAPE? CBP expects it will take approximately 45 days from acceptance to review to liquidation for a validated entry, but notes that there is room for delays if a compliance issue necessitates further review. 

It also intends to expand the capacities of CAPE during Phase Two and beyond, granting it further tools to ensure compliance, streamline revenue enforcement, and process entries for which “liquidation is final.” They also note a desire to increase their ability to process “non-[ABI] entries where no entry summary lines exist.”

What Do You Do Now? 

There are a few key things you need to be considering right now as an importer watching CAPE unfurl. The first and most important point is that this is a golden opportunity for CBP to review the minutiae of your submitted entries and ensure they are up to par. This means that, now, ahead of your submission date, is the ideal time to get your house in order and make sure every ‘T’ is crossed and ‘I’ dotted. CBP has already indicated that they will be ‘spot-checking’ refund submissions to identify compliance issues and offset refunds. Checking your entries now will ensure that your CAPE filing isn’t denied on a technicality, and you will get your money back sooner. 

Next, if you have not registered for both the ACE and ACH Portals, then now is the time to do so. This process relies on both of these services, and they can provide vital information and insights into your imports even before the refunds start arriving. 

The ACE Portal is the primary point of contact with CBP and will be the keystone of the IEEPA refund process. Registration in this portal involves confirming your 5106 information with CBP, a process that can be time-consuming - particularly right now when interest is at an all-time high, so you are encouraged to verify this as soon as you can. Of course, PCB can help query this information, and we can do so more expeditiously than if you were to attempt it yourself.  

ACH manages the payments of imports and serves as a convenient way to interact with CBP financially. In addition to streamlining the process and saving you money on disbursement fees, it is currently the only way that CBP distributes refunds, so registration is critical. It is also worth noting that simply registering in ACH is not the same as preparing to process refunds within ACH - there is an additional step. Be careful and ensure you have taken the necessary steps to receive your refund. 

Finally, the question of protests is a bit murky. Additional protests are an option, and PCB can help with them, but they should be carefully considered before proceeding. The truth is that we don’t know exactly what the full shape of this will be, and to what extent protests will hinder your refund efforts. 

What we do know is that protested entries may already preclude those goods from being resolved in Phase 1, so they can add a layer of complexity to a process for which waiting for CAPE may be the more cost-effective solution. As always, exercise caution and work closely with your Trade Advisor - especially in these early moments - to find the strategy that works best for you. 

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PCB can help you with virtually every step of this process. From helping you pull together your entries and preparing them for submission to providing you with what you need to register for ACE, all the way to offering support with ACH and guiding you through the protest process, we have the support you need to hit the ground running.  

With the help of our team of experts, setting you on the right course, you’ll find that this can be a complex process made simple, and you’ll be ready to receive your refund before you know it.

Get in touch today to get started!