CBP has issued updated guidance regarding the process for obtaining refunds of duties collected under the International Emergency Economic Powers Act (IEEPA). Importers should note the following key points when preparing to file for refunds:

• Phase 1 of the CAPE functionality in ACE is scheduled to go live on April 20, 2026, at 8:00 AM EDT. Importers may begin submitting CAPE Declarations at that time.
• Refunds must be requested through the Consolidated Administration and Processing of Entries (CAPE) functionality in ACE. Post Summary Corrections (PSCs) cannot be used to request IEEPA refunds.
• A CAPE Declaration must be submitted via the ACE Portal using a CSV file that includes only entry numbers. Each submission may include up to 9,999 entries, and multiple submissions are permitted.
• CAPE Declarations may only be filed by the Importer of Record or the authorized broker who filed the entries.
• CBP will validate all submissions. Entries may be rejected if they include:
  • Open or suspended protests
  • Reconciliation, drawback, or USMCA deferral entries
  • AD/CVD entries pending liquidation
  • Entries more than 80 days past liquidation
  • Entries with reporting inconsistencies
• Entries that fail validation can be corrected and resubmitted on a new CAPE Declaration.
• Do not include entries where a surety paid IEEPA duties. CAPE Declarations should also be filed prior to submitting any drawback claims.
• If a protest was filed solely to obtain an IEEPA refund and the entry is within 80 days of liquidation, importers may withdraw the protest and submit the entry through CAPE for faster processing.
• Once accepted, CBP will remove IEEPA duties, recalculate the entry, and issue a refund equal to the difference between duties paid and duties owed, including applicable interest.
• Unliquidated entries will generally be scheduled for liquidation within 45 days of CAPE acceptance. Most refunds are expected within 60 to 90 days, depending on CBP review and processing.
• Refunds for warehouse entries and warehouse withdrawals will be processed in the normal course once all withdrawals are completed and the entry is ready for liquidation.
• Refunds will be consolidated and issued as a single payment rather than on an entry-by-entry basis.
• Any outstanding debts owed to CBP will be deducted from the total IEEPA refund prior to payment.
• All refunds will be issued electronically via ACH. Importers should ensure ACH enrollment is in place to avoid delays.
• Refund activity can be monitored in ACE using the REV-615 CAPE Refunds Trade Report.

We will continue to provide additional updates on CAPE as they are released from CBP. We have linked the CAPE training guide and IEEPA website for your convenience. The most important items to address in preparation of the launch of CAPE are to setup your ACE importer portal with ACH information and request a CSV file of eligible entries from your broker. As always, please reach out should you have any questions on the process.