On April 28, 2026, Brandon Lord, Executive Director of the U.S. Customs and Border Protection (CBP)’s trade policy and programs directorate, filed a declaration (April 28 Declaration) with the U.S. Court of International Trade (CIT). The filing provided an update on the new International Emergency Economic Powers Act (IEEPA) tariff refund process, named Consolidated Administration and Process Entries (CAPE), that went live to on April 20, 2026.
Background
On April 20, 2026, the first phase of CAPE functionality within the Automated Commercial Environment (ACE) went live, permitting refunds of IEEPA tariffs imposed on certain entries. Phase I CAPE functionality was designed to process CAPE Declarations (i.e., refund requested) for two types of entries:
- Certain unliquidated entries
- Certain liquidated entries within 80 days of the date of liquidation.
Other IEEPA tariffs, including liquidated entries more than 80 days past the date of liquidation, will be eligible for filing in a subsequent phase of the CAPE system. The timing of that additional functionality has yet to be disclosed.
CBP is expecting that CAPE Declarations that pass the file validation and the entry validation to be refunded within 60-90 days.
April 28 CBP Declaration
In its April 28 declaration, the CBP provided quantitative insights into the use of the CAPE portal as of the evening of Sunday, April 26, 2026:
- Over 75,000 CAPE Declarations submitted, of which 47,315 passed file validation
- A total of 11,222,927 entries passed entry validation and were accepted for IEEPA tariff refund processing
- A total of 2,124,394 entries were rejected for processing in the entry validation testing
- Of the 11,222,927 entries that did pass the entry validation testing, 1,746,000 entries have already been liquidated without IEPPA tariffs and are in the refund process
According to CBP’s own assessment, the CAPE portal is functioning well, and approximately 63% of all CAPE Declarations passed file validation, meaning the formatting was correct, the file wasn’t corrupt, etc. Additionally, approximately 84% of all entries on the CAPE Declarations that passed file validation passed entry validation, meaning the entries.
In addition to the April 28 CBP Declaration, the CBP is proactively updating its website and Cargo Systems Messaging Service (CSMS) with helpful information such as:
- ACE Entry Summary Error Dictionary
- Electronic Refund Enrollment in the ACE Portal
- IEEPA Duty Refunds FAQ
Affected parties should regularly check the CBP website for up-to-date information on the IEEPA tariff refund processing through the CAPE portal.
Your Guide Forward
Cherry Bekaert established a cross-functional team of professionals to help advise and support our clients with the downstream effects when tariffs and tariff refunds impact tax, accounting, audit and financial reporting functions.
If you have questions about preserving your rights or about any other legal or trade implications that may exist, we recommend reaching out to appropriate legal counsel.
Related Insights
- Alert: IEEPA Tariff Refunds: Court of International Trade Orders & What Importers Should Do Next
- Alert: Amended IEEPA Order, Steps to Take for Final Liquidated IEEPA Tariff Entries
- Alert: U.S. Customs and Border Protection Files Update on IEEPA Tariff Refunds
- Alert: IEEPA Tariff Refund Update: Phase I CAPE Functionality Set for April 20, 2026
