IEEPA tariff refunds move to a new CBP portal on April 20
Beginning April 20, importers of record (or their authorized customs brokers) may submit IEEPA tariff refund requests electronically through the ACE Secure Data Portal using the CAPE tool.
Phase 1 of CAPE is intentionally limited to lower‑complexity scenarios, including:
- Unliquidated entries subject to IEEPA duties
- Entries liquidated within approximately 80 days of the filing date
- Certain suspended, extended or under‑review entries (with refunds issued upon liquidation)
CBP has indicated that Phase 1 is expected to capture a significant portion of eligible entries. Additional phases planned later in 2026 are intended to address more complex fact patterns, including reconciliation entries, drawback claims and historically liquidated entries.
Once a submission is accepted, CBP anticipates refunds to be issued electronically within approximately 60–90 days, inclusive of statutory interest, subject to standard compliance review.
Why the new process changes refund strategy for importers
By design, the CAPE process is intended to be more streamlined than traditional refund or protest mechanisms. In practice:
- CAPE submissions rely on a structured CSV file rather than narrative claims or extensive supporting documentation.
- Refunds are consolidated and system‑processed, reducing administrative friction.
- Importers may submit directly, if preferred, without reliance on customs brokers.
While administratively efficient, successful CAPE submissions still depend on accurate data, proper access controls and thoughtful execution. Once a CAPE declaration is accepted, it cannot be amended. If additional eligible entries are identified after filing, a new declaration must be submitted. Each entry can appear on only one accepted declaration.
What importers can do now to prepare for CAPE filings
Companies that believe they paid IEEPA tariffs should begin preparing by:
- Confirming ACE Portal access (importer of record or delegated authority)
- Verifying that ACH refund enrollment is active and current
- Identifying entries potentially eligible for Phase 1 processing
- Determining whether to pursue a broker‑led approach or partner with a trusted advisor
Early preparation may help accelerate refunds and reduce the risk of bottlenecks as filing volumes increase following the April 20 launch.
How trade and tariff advisors support IEEPA refund claims
The CAPE process is more systematic than a traditional protest, but it is not without complexity.
Entries that appear eligible may have compliance flags that CBP will catch during validation, triggering rejections that require follow-up. Businesses with large import programs may need to coordinate between multiple brokers, reconcile entry records across multiple ports, and sequence their filings to avoid inadvertently locking out eligible entries with an improperly structured declaration.
For importers operating in industries with high tariff exposure—such as consumer goods, electronics, industrial equipment, automotive parts—the aggregate duty recovery can be substantial. Getting the filing right the first time, and understanding which entries fall into which phase, can meaningfully accelerate the timeline.
An experienced trade and tariff advisor can help businesses throughout the CAPE refund process by:
- Identifying potentially eligible entries and assessing exposure under the IEEPA refund framework using proprietary analytics tools
- Assisting with data preparation and validation for CAPE submissions
- Supporting internal controls, documentation, and governance related to tariff recovery
- Advising on refund strategy, including identification and mitigation of compliance anomalies that could delay or jeopardize refunds
- Addressing related customs and trade considerations before, during, and after the refund process
- Maintaining compliance and minimizing operational disruption
Learn more about RSM’s trade and tariff advisory services.
