CBP CAPE SYSTEM LIVE TODAY: A New Era for IEEPA Duty Refunds
As of April 20, 2026, U.S. Customs and Border Protection (CBP) has officially launched Phase 1 of the Consolidated Administration and Processing of Entries (CAPE) system within the ACE Secure Data Portal. This long-anticipated development introduces a centralized, electronic pathway for submitting refund requests tied to duties imposed under the International Emergency Economic Powers Act (IEEPA), marking a meaningful shift toward modernization in trade processing.
The CAPE System and How It Works
At its core, CAPE is designed to simplify what has historically been a fragmented and manual process. Importers and customs brokers can now submit IEEPA refund claims directly through ACE by uploading a standardized CSV file—referred to as a CAPE Declaration—that lists the relevant entry numbers. Each submission can include up to 9,999 entries, and multiple filings are permitted, offering flexibility for high-volume filers.
Once submitted, the system performs a series of automated validations to ensure both the file structure and the underlying entry data meet CBP requirements. If issues are identified at the file level, the submission is rejected and must be corrected and resubmitted. However, if only certain entries fail validation, those entries are removed while the remainder of the claim continues processing. This approach allows filers to move forward efficiently without restarting the entire submission process.
For entries that pass validation, CAPE triggers a significant downstream effect within ACE. The system removes the applicable IEEPA duty lines—typically associated with HTS Chapter 99—and recalculates the duties owed. This results in an updated entry summary, after which CBP will review the claim and proceed with liquidation or reliquidation as appropriate. Refunds are then issued, generally consolidated by recipient and liquidation date, streamlining what has traditionally been a disjointed reimbursement process.
Phase 1 of CAPE focuses on a defined subset of entries. Most notably, it includes unliquidated entries as well as those within 80 days of liquidation. It also accommodates entries in suspended, extended, or under-review status, along with certain warehouse-related entries. At the same time, CBP has excluded several categories from this initial rollout, including reconciliation entries, drawback claims, protested entries, and entries subject to AD/CVD liquidation instructions. These exclusions suggest that future phases of CAPE will continue to expand functionality and coverage.
It is important for filers to understand that CAPE operates exclusively within the ACE Portal environment. At this stage, there is no integration with ABI or other EDI channels, and CBP has explicitly prohibited the use of Post Summary Corrections (PSCs) to initiate IEEPA refund requests. This reinforces the agency’s intent to centralize and standardize the refund process through a single digital workflow.
From a financial perspective, refunds issued through CAPE are processed electronically via Automated Clearing House (ACH). This introduces an operational requirement that importers ensure their refund banking information is properly established in ACE. Notably, refund account details are maintained separately from duty payment accounts, and failure to enroll in ACH refunds may result in delays or rejected payments.
CAPE also enhances visibility into refund activity. Importers can monitor the status of their claims through ACE reporting tools, including reports that track successful refunds as well as those rejected due to missing ACH enrollment. This added transparency is expected to improve reconciliation and internal tracking for trade compliance teams.
How CAPE Changes The Paths To A Refund
It is also important to understand how CAPE fits within the broader landscape of trade remedies and legal rights. CBP has made clear that Post Summary Corrections (PSCs) cannot be used to initiate IEEPA refund claims, reinforcing that CAPE may be the exclusive administrative pathway for these requests. This is also suggested by the fact that entries that are subject to an open protest are not eligible for CAPE submission in Phase 1, effectively requiring importers to choose their procedural avenue carefully. Notably, official CBP guidance does not indicate that pending litigation—such as cases before the Court of International Trade (CIT)—precludes CAPE filings, suggesting that judicial and administrative remedies may, at least for now, operate in parallel. However, CAPE’s scope is limited to unliquidated entries and those within 80 days of liquidation, meaning that older entries fall outside its reach. As a result, litigation may still be necessary to preserve refund rights for entries beyond CAPE eligibility, particularly where statutory deadlines are at issue. With CAPE newly implemented, it remains uncertain how the CIT will approach ongoing or future cases involving IEEPA duties, and whether the availability of an administrative refund mechanism will influence judicial strategy or outcomes.
Conclusion
Taken together, the launch of CAPE represents a significant step forward in CBP’s broader effort to digitize and streamline trade processes. While Phase 1 is intentionally limited in scope, it establishes the foundation for a more efficient and transparent duty refund framework. For importers, this creates both opportunity and responsibility—opportunity to recover eligible duties more efficiently, and responsibility to ensure data accuracy, proper formatting, and system readiness.
As CAPE evolves, companies that proactively align their processes with this new framework will be best positioned to take advantage of its benefits. At Liang + Mooney, PLLC, out tariff lawyers are here to help you navigate through this ever changing IEEPA refund process. We invite you to contact us to schedule a consultation.