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IEEPA Tariff Refund Update: Phase I CAPE Functionality Set for April 20, 2026

Alert

April 15, 2026

U.S. Customs and Border Protection (CBP) announced that Phase I of the new tariff refund technology — Consolidated Administration and Processing Entries (CAPE), which will operate within the Automated Commercial Environment (ACE) — will be available for use on April 20, 2026, as of 8:00 a.m. ET. CBP expects refunds to be issued within 60 to 90 days after a CAPE Declaration, or a refund claim, is filed and accepted.

Background

In its March 6, 2026, filed declaration, the CBP provided details on the breadth of entries for which refunds of the IEEPA tariffs could be due:

Over 330,000 importers of record
Over 53 million entries with IEEPA tariff deposits or payments
Approximately $166 billion of IEEPA tariff payments and deposits made

CBP noted that processing this volume of refunds under its existing procedures would require 4,431,161 working hours. (To give this hour commitment context, that would be 533,896 days of eight-hour days, or 184,632 days if CBP resources could work 24 hours a day nonstop).

CBP requested a 45-day extension to develop a new process, which the U.S. Court of International Trade (CIT) granted. The deadline for refund processing to begin was set for April 20, 2026. At prescribed intervals, CBP was required to provide updates on its progress in the development of CAPE and updating of ACE.

On March 12, 2026, CBP filed an order that outlined the proposed CAPE functionality, noting a phased rollout would be necessary. CBP projects that Phase I of CAPE will process approximately 63% of those entries for which refunds are due.

CBP Announcement

CBP announced that CAPE Phase I functionality will be available to accept CAPE Declarations as of April 20, 2026. CBP appears to have kept true to its March 31, 2026, declaration, announcing that phase one will be limited to the following two types of entries:

Certain unliquidated entries
Certain entries liquidated within the last 80 days

CAPE Declaration

In order to apply for a refund (file a CAPE Declaration), importers of record and customs brokers must first establish an ACE Secure Data Portal account. Next, once registered, complete the ACH tab with banking information (all refunds will be issued electronically). The company should then be in a position to complete and file the CAPE Declaration.

A CAPE Declaration will consist of an uploaded comma-separated values (CSV) file containing no more than 9.999 entry numbers. The template will be available via the “Upload” button in the CAPE tab. Once file validations and entry-specific validations are completed, those entries on the CAPE Declaration accepted will be assigned a unique CAPE claim number.

The anticipated timing for refunds being issued is 60 to 90 days after a CAPE Declaration has been filed and accepted.

Additional details on the CAPE Declaration and the other three components of CAPE functionality (Mass Processing, Liquidation/Reliquidation and Refund) can be found in CBP’s most recent CSMS.

Subsequent Phases

We will continue to provide information on subsequent phases of the CAPE system, which are expected to handle liquidate entries over 80 days old that have yet to be finalized, as well as finalized entries, as developments occur.

Your Guide Forward

If you have questions about preserving your rights, or other legal or trade implications that may exist, we recommend reaching out to appropriate legal counsel.

In addition to following CBP-aligned preparations for proceeding with refund requests, we are advising our clients to prepare for the technology launch by gathering relevant data, examining potential liabilities, and modeling tax, transfer pricing, and financial statement impacts.

Cherry Bekaert established a cross-functional team of professionals to help advise and support our clients on the downstream effects when tariffs and tariff refunds impact tax, accounting, audit, and financial reporting functions.

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