Understanding CBP's CAPE System: How to File for Your IEEPA Refund

What Is CAPE?

CAPE stands for Consolidated Administration and Processing of Entries. It is a new module within CBP's Automated Commercial Environment (ACE) Portal, built specifically to handle the unprecedented volume of IEEPA tariff refund claims following the Supreme Court's February 2026 ruling in Learning Resources, Inc. v. Trump.

Before CAPE, the only mechanisms for recovering overpaid duties were traditional protests and court filings. Given that 53 million entries across 300,000+ importers are affected, those mechanisms alone would overwhelm both CBP and the Court of International Trade. CAPE was designed to process the majority of these claims efficiently and at scale.

Phase 1 of the CAPE system launched in April 2026. It covers unliquidated entries and entries liquidated within the past 80 days, which represent approximately 63% of all eligible IEEPA entries. Later phases will expand coverage to additional entry categories.

Who Can File Through CAPE?

CAPE claims must be filed by the Importer of Record (IOR) or an authorized agent (typically your customs broker) acting on the IOR's behalf. The IOR on the CAPE filing must match the IOR on the original entry.

Your entries are eligible for CAPE Phase 1 if they meet all of the following criteria:

• The entry status is "Accepted" in ACE
• The control status is "CBP" (meaning CBP holds control of the entry, not another agency)
• The entry contains at least one IEEPA-specific HTS code
• The entry is either unliquidated or was liquidated within the past 80 days
• The entry is not flagged for Reconciliation
• The entry is not subject to an active protest
• The entry does not fall into an excluded entry type

Excluded Entry Types

The following entry types are not eligible for CAPE Phase 1:

• Type 08 — Duty Deferral entries
• Type 09 — Reconciliation entries
• Type 23 — Temporary Importation under Bond (TIB) entries
• Type 47 — Drawback entries

Additionally, entries involved in active antidumping or countervailing duty (AD/CVD) proceedings may be excluded depending on the specifics of the case.

If your entries fall into any of these categories, you will need to pursue a refund through a traditional protest (if within the 180-day window) or a 28 U.S.C. 1581(i) case before the Court of International Trade (two-year statute of limitations, deadline approximately February 2028).

What You Need Before Filing

Before you submit a CAPE claim, ensure the following are in place:

1. ACE Portal access. You must have an active ACE account with appropriate permissions. If your broker files on your behalf, confirm they have the necessary authorization.

2. ACH enrollment. CBP ceased issuing paper refund checks on February 6, 2026. All refunds are disbursed via ACH. If you are not enrolled, you cannot receive payment regardless of claim status. Enroll through the ACE Portal with valid banking information linked to your IOR number.

3. Entry inventory. Compile a complete list of all entry numbers on which you paid IEEPA duties. Your customs broker, trade management system, or ACE account should contain this data.

4. Validated entry numbers. Each entry number must be exactly 11 alphanumeric characters. Verify formatting before preparing your file.

How to Prepare: Submission Is Just the Start

Takeaway. April 20 is not a finish line. It is the day you raise your hand and say please refund me. What decides whether you keep the money is the audit CBP does on your entries before it cuts the check. Your job between now and then is to make every entry defensible before you put it into a claim.

CBP is going to audit your claim before paying it. In a court filing in Atmus Filtration Inc. v. United States, CBP said it "still requires a review period to ensure no violation of other Customs laws and no other duties, taxes, or fees are owed (e.g., antidumping duties, Section 301 duties, Section 232 duties, etc.)." Every CAPE Declaration you file is a clean, curated list of your IEEPA-era entries, and CBP will audit that list. HTS classification, declared value, country of origin, Incoterms, related-party pricing, program claims, MPF/HMF math, all of it. If you overpaid IEEPA but underpaid anything else, the refund can be reduced, zeroed out, or turned into a bill. A sloppy entry can pull the thread on penalties, prior disclosures, or a formal audit.

CBP also has reason to think the IEEPA era was unusually fraud-prone. On April 7, 2026, the New York Times published an investigation by Ana Swanson, "'Definitely a Sham': As Tariffs Climb, Trade Fraud and Accounting Tricks Proliferate", which reported, based on ImportGenius data, that the average declared value of a 20-foot container arriving from China dropped by nearly 40% between January 2025 and February 2026, while container values from other origins stayed flat. Flexport CEO Ryan Petersen told the Times, "We're seeing just total, rampant fraud," and separate Bloomberg reporting in February 2026 documented a $112 billion gap between what China said it exported to the U.S. and what CBP recorded arriving. CBP spokeswoman Trish Driscoll told the Times that "duty evasion schemes can be used to drive down declared customs values," and CBP is pattern-matching on exactly that data. A CAPE Declaration is the curated list of IEEPA-era entries CBP would otherwise have to hunt for.

Don't assume CBP can't look closely. They already are — and they're getting better fast.

A common objection we hear: "Customs doesn't have the capacity to scrutinize every entry. They'll just rubber-stamp refunds." The data says otherwise, on every dimension that matters.

The audit pace has already accelerated dramatically. CBP publishes audit results in its monthly operational updates, and the numbers tell a clear story. In March 2025 alone, CBP completed 71 audits and identified $310 million in duties and fees owed. For context, in the entire prior fiscal year, CBP collected $117.67 million from 417 audits. By April 2025, roughly halfway through the fiscal year, CBP had already completed around 200 audits and reached $134 million — a record pace. In May 2025, another 67 audits identified $139 million more. This is not business as usual. Multiple major trade law firms have noted that CBP's posture has shifted from trade facilitation to trade enforcement, a structural change they expect to continue and accelerate in 2026, driven by CBP's investment in AI.

The optimal move: audit before you claim. Audit every impacted entry to a standard you could defend to CBP cold, before it ever goes into a Declaration. No surprise bills. No penalty. No give-backs.

Step-by-Step Filing Process

Step 1: Prepare Your CSV File

CAPE claims are submitted via a CSV file uploaded through the ACE Portal. The file format is straightforward but must be followed precisely:

• Column A contains entry numbers, one per row
• Row 1 is a header row (e.g., "Entry Number")
• Entry data begins in Row 2
• Each entry number must be 11 alphanumeric characters
• Maximum file size: 1 MB
• No additional columns, formatting, or metadata

A properly formatted file looks like this:

| Entry Number | |---| | A1B2C3D4E5F | | G6H7I8J9K0L | | M1N2O3P4Q5R |

Save the file in CSV format. Do not submit Excel (.xlsx) files or other formats.

Step 2: Log Into the ACE Portal

Navigate to the ACE Portal and log in with your credentials. Access the CAPE module from the main navigation. If you do not see the CAPE option, verify that your account has the appropriate permissions or contact your ACE account manager.

Step 3: Upload Your CSV

Within the CAPE module, select the option to submit a new claim. Upload your prepared CSV file. The system will immediately perform file-level validation before processing individual entries.

Uploading the file is the start of validation, not the start of the refund clock. The meaningful timing window begins only after CBP accepts the declaration.

Step 4: Review Validation Results

After upload, CAPE validates your submission at two levels:

File-level validation checks the overall structure of your CSV. If the file format is incorrect (wrong delimiters, invalid encoding, exceeds 1 MB), the entire file is rejected. You must correct the file and resubmit.

Claim-level validation checks each individual entry number against CBP records. Each entry will receive one of three outcomes:

• Accepted — The entry is eligible and will be processed for refund
• Accepted with Errors — The entry is partially eligible; some line items may not qualify (e.g., non-IEEPA HTS codes on the same entry). Eligible portions will be processed.
• Rejected — The entry does not meet CAPE eligibility criteria. The rejection reason will be provided.

Step 5: After Acceptance, What Happens Next

After a CAPE Declaration is accepted, here is what actually happens:

1. CBP reviews and (re)liquidates each valid entry — CBP has stated this takes up to 45 days from acceptance.
2. Refund is disbursed via ACH after (re)liquidation, with statutory interest, consolidated by liquidation date.
3. Total target window: 60–90 days from CBP acceptance of the Declaration, unless a compliance issue triggers further review. (The clock starts at acceptance, not at upload.)

Step 6: Address Rejections, Then Monitor Status

For file-level errors, correct the formatting issue and upload a new file.

For claim-level rejections, review the specific rejection reasons provided by CAPE. Common rejection reasons include:

• IOR mismatch between the claim and the original entry
• Entry status is not "Accepted"
• Control status is not "CBP"
• No IEEPA HTS code on the entry
• Entry is flagged for Reconciliation
• Entry type is excluded (08, 09, 23, or 47)

You may resubmit rejected entries in a new CSV file after resolving the underlying issue. Entries that were accepted do not need to be resubmitted.

For accepted entries, monitor the claim inside the ACE Portal and watch the Client Service Message System (CSMS) for updates on timing, system changes, and later CAPE phases.

Common Filing Mistakes to Avoid

Based on early CAPE submissions, the following errors are the most frequent causes of rejection or delay:

• Incorrect entry number format. Entry numbers must be exactly 11 alphanumeric characters. Leading zeros, dashes, and spaces will cause rejections.
• Wrong file format. The system accepts CSV only. Excel files, PDFs, and other formats will be rejected at the file level.
• IOR mismatch. The IOR on the claim must match the IOR on the original entry. If your company has changed IOR numbers, this requires resolution before filing.
• Including ineligible entries. Submitting entry types 08, 09, 23, or 47 will result in claim-level rejections. Filter these out before uploading.
• Filing without ACH enrollment. Even if your claim is accepted, you cannot receive payment without ACH enrollment. Complete this step first.

What If Your Entries Are Not Eligible for CAPE?

Not all IEEPA entries qualify for CAPE Phase 1. If your entries are excluded, you have two alternative paths:

Protest (19 U.S.C. 1514)

You may file a protest for any liquidated entry within 180 days of the liquidation date. This is the appropriate mechanism for entries that were liquidated more than 80 days ago but are still within the protest window. Do not wait for CAPE Phase 2 if your protest deadline is approaching.

Court of International Trade (28 U.S.C. 1581(i))

For entries where the protest window has closed, you may file a case with the CIT under its residual jurisdiction. The statute of limitations is two years from the date the cause of action accrued, placing the deadline at approximately February 2028.

This is a legal proceeding that requires counsel. If you have significant refund amounts tied to entries outside both CAPE and protest eligibility, engage experienced trade litigation attorneys promptly.

Staying Informed

CBP communicates all CAPE updates, procedural changes, and phase expansion timelines through its Client Service Message System (CSMS). If you are not subscribed to CSMS, do so immediately. This is the primary channel through which CBP announces:

• New CAPE phases and expanded eligibility criteria
• System maintenance windows and downtime
• Changes to filing requirements or validation rules
• Processing timeline updates

You can subscribe to CSMS through the CBP website. Filter for trade-related messages to ensure you receive relevant notifications without excessive volume.

Key Takeaways

• CAPE is the fastest path to your IEEPA refund for eligible entries
• Phase 1 covers ~63% of affected entries (unliquidated + liquidated within 80 days)
• Filing requires a simple CSV upload through the ACE Portal
• ACH enrollment is mandatory before you can receive any refund
• Filing is the start of CBP review, not the finish line
• Straightforward accepted declarations can move through review in up to 45 days, but clean claims still often take about 60 to 90 days from acceptance to payout
• Audit each impacted entry before filing so a refund request does not turn into a new customs problem
• Entries outside CAPE eligibility require protests or 1581(i) court filings
• Monitor CSMS for all CBP updates on the refund process

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The CAPE system was built to return your money efficiently. But it only works if you file. Every day without a claim is a day your refund sits with the government instead of in your account.

TariffRefund.com helps importers prepare and file CAPE claims with confidence. If you need help compiling your entry data, formatting your CSV, or understanding which of your entries qualify, get started today.