What Is the IEEPA Tariff Refund Program — and Why It Matters to Your Business

The U.S. Supreme Court ruled that tariffs collected under the International Emergency Economic Powers Act (IEEPA) were unlawful, and U.S. Customs and Border Protection (CBP) is now required by court order to issue refunds to affected importers. To manage the unprecedented volume of claims — estimated at up to $175 billion in total duty refunds — CBP built a new electronic system called the Consolidated Administration and Processing of Entries (CAPE) tool, deployed inside the ACE Secure Data Portal on April 20, 2026.

CAPE is now the exclusive filing mechanism for Phase 1 IEEPA refund claims. There is no alternative route. Importers who miss the Phase 1 eligibility window will be pushed to later phases — which are expected to take significantly longer to process.

AIT Tahipo LLC is ready to file on your behalf today.

Understanding CAPE Phase 1 Eligibility: Are Your Entries Covered?

Phase 1 of CAPE covers approximately 63% of all entries on which IEEPA duties were paid. To qualify, an entry must meet one of the following conditions:

• The entry is unliquidated (CBP has not yet finalized the duty calculation), or
• The entry was liquidated within the preceding 80 days, meaning it still falls within the 90-day voluntary reliquidation window under 19 U.S.C. § 1501.

The following entry types are excluded from Phase 1 and will be addressed in future CAPE phases:

• Entries flagged for reconciliation (including Type 09 Reconciliation Summary entries)
• Entries subject to an active drawback claim (Type 47)
• Entries subject to antidumping or countervailing duty (AD/CVD) orders
• Entries currently under protest, suspension, or CBP review
• Warehouse entries (refunds issued at liquidation)

Entries that contain no IEEPA-related HTS Chapter 99 duty codes are not eligible for any CAPE phase. Not sure where your entries stand? AIT Tahipo performs a full eligibility screening before filing — so nothing is submitted that shouldn’t be.

How the CAPE Filing Process Works — Step by Step

CBP designed CAPE to consolidate thousands of entries into a single submission, rather than processing refunds one entry at a time. Here is how the process flows from start to refund:

1. ACE Portal Account Verification — The Importer of Record (IOR) must have an active ACE Portal account with an Importer sub-account. Without this, CAPE submissions cannot be made and refunds cannot be received.
2. ACH Refund Enrollment — The IOR must enroll a U.S. bank account specifically for refunds through ACE. Having ACH set up for duty payments is not sufficient — a separate refund-specific ACH enrollment is required. CBP will hold approved funds until valid banking information is on file.
3. Entry Compilation and Eligibility Screening — All potentially eligible entries are compiled into a list and screened against Phase 1 criteria, including liquidation status, HTS Chapter 99 duty codes, and exclusion categories.
4. CAPE Declaration Preparation — Eligible entry numbers are entered into a CSV file (the CAPE Declaration template) following CBP’s exact formatting requirements. Each declaration can contain up to 9,999 entries, and multiple declarations may be submitted.
5. Submission Through the ACE CAPE Tab — The CAPE Declaration is uploaded through the CAPE tab in ACE. CBP runs two rounds of automated validation: one on the declaration file itself, and a second on each individual entry number listed.
6. CBP Review and Reliquidation — Once accepted, CBP removes the applicable IEEPA HTS Chapter 99 codes from each entry summary, recalculates duties as if IEEPA had never applied, and adds statutory interest under 19 U.S.C. § 1505(c). Unliquidated entries are set to liquidate approximately 45 days after acceptance. Already-liquidated entries reliquidate the next business day.
7. Consolidated Refund Issuance — Refunds are consolidated by IOR and liquidation date and paid via a single ACH deposit. For most entries, importers can expect payment within 60 to 90 days of CAPE Declaration acceptance, barring compliance review.

AIT Tahipo handles every step of this process for you.

Why Errors Are Costly — and Why Accuracy Matters More Than Speed

CBP has made one thing clear in its official guidance: if a CAPE Declaration contains a single error, the entire submission is returned and the importer must correct and resubmit from scratch. Common error triggers include:

• HTS classification mismatches between the original entry and the refund filing
• Valuation inconsistencies or country-of-origin discrepancies
• Entry numbers that are ineligible for Phase 1 (e.g., entries under protest)
• Missing or incorrect ACH banking information in ACE
• Duplicate entry submissions

Early reports since the April 20 launch have confirmed that the CAPE portal is flagging a high volume of submissions with errors, including the common “Unable to calculate duty” system message, which routes claims into manual CBP review and significantly delays processing. Beyond the initial refund, CBP has signaled that CAPE submissions may be subject to post-refund audit activity — meaning a hastily filed, inaccurate declaration can create compliance exposure long after the refund is issued.

AIT Tahipo’s pre-filing audit process checks for all known error triggers before a single entry number is submitted.

For official CBP guidance, see: CBP IEEPA Duty Refunds — Official Resource Page

IEEPA Refund Interest: What You Are Owed Beyond the Principal

Importers are entitled to more than just their duty principal back. Under 19 U.S.C. § 1505(c), CBP must add statutory overpayment interest running from the date the original duties were paid through the date of liquidation or reliquidation. For the quarter beginning January 1, 2026, the applicable interest rates are:

• 7% per annum for noncorporate importers
• 6% per annum for corporate importers

For importers who paid IEEPA duties over an extended period, this interest component can represent a meaningful addition to the total refund amount. AIT Tahipo’s entry review process accounts for interest eligibility as part of the full refund calculation.

Learn more about our full range of customs compliance services at AIT Tahipo. [INTERNAL: /services]

The Phase 1 Deadline Is Not the Only Deadline to Watch

CAPE processes refund declarations on a first-in, first-out basis. Importers who file earlier move to the front of the queue. Given that over 56,000 U.S. importers had pre-registered for IEEPA refunds as of early April — before CAPE even launched — competition for early processing slots is intense.

Beyond queue position, a harder deadline applies: entries liquidated more than 80 days ago fall outside Phase 1 eligibility. Every day of delay is a day that additional entries age out of the Phase 1 window. Future phases are expected to take longer to process and will involve more complex CBP review.

Importers who are unsure of their entry liquidation dates should contact AIT Tahipo immediately for a free eligibility screening.

Frequently Asked Questions: IEEPA Tariff Refunds and the CAPE Portal

Official Resources for IEEPA Tariff Refund Filers

• CBP Official IEEPA Duty Refunds Page — The authoritative source for CAPE instructions, eligibility rules, and the CAPE Declaration template.
• ACE Secure Data Portal — Where CAPE Declarations are submitted and ACH refund banking information is configured.
• CBP CSMS #68340863 — CAPE Deployment Bulletin (April 13, 2026) — The official CBP system message with Phase 1 technical specifications.

For questions about how these resources apply to your specific entries, Contact AIT Tahipo directly. We monitor CBP updates continuously and will keep your filing aligned with the latest requirements.