CBP Launches CAPE: A New Era for IEEPA Duty Refunds
After weeks of anticipation across the trade community, U.S. Customs and Border Protection (CBP) has officially released Phase 1 guidance for its new Consolidated Administration and Processing of Entries (CAPE) functionality—marking a significant shift in how International Emergency Economic Powers Act (IEEPA)-related duty refunds will be processed.
The announcement, issued through CBP’s Cargo Systems Messaging Service (CSMS), follows a series of court-driven developments that effectively dismantled the collection of certain duties imposed under the IEEPA. What remained uncertain until now was how CBP would manage the enormous administrative burden of refunding those duties. CAPE is the agency’s answer.
CAPE Phase 1 Go-Live
CBP has confirmed that Phase 1 of the CAPE functionality will go live at 8:00 AM EDT on April 20, 2026. From that point forward, importers and their authorized brokers will be able to begin submitting CAPE Declarations through the Automated Commercial Environment (ACE )Portal.
Importers should prepare entry lists in advance and confirm ACE access and ACH enrollment are in place to avoid delays once filing begins.
With the April 20 rollout expected to bring high filing volumes and a new process.
Importers should expect:
System Delays
Validation Issues
Processing Bottlenecks
Allow extra time for submissions and remain flexible during the first week as CBP and the trade community work through initial challenges.
From Court Orders to System Build-Out
The roots of CAPE trace back to early March, when the Court of International Trade (CIT), following direction from the Court of Appeals for the Federal Circuit, ordered CBP to begin unwinding IEEPA duty collections. Specifically, CBP was directed to:
Liquidate unliquidated entries without IEEPA duties, and
Reliquidate non-final entries to remove those same duties
While the legal directive was clear, the logistics were anything but. With potentially thousands of impacted entries per importer, CBP quickly paused immediate implementation to develop a scalable solution. CAPE built within the ACE is that solution.
A Shift Away from Entry-by-Entry Refunds
At its core, CAPE represents a departure from the traditional, highly manual refund process.
Instead of relying on protests, Post Summary Corrections (PSCs), or piecemeal adjustments, CBP is moving toward a bulk-processing model.
Under Phase 1, importers (or their authorized brokers):
Submit a single CAPE Declaration via the ACE Portal.
Upload a simple CSV file containing entry numbers.
Include up to 9,999 entries per CSV file.
No values, no duty calculations, just the entry numbers themselves.
Behind the scenes, ACE takes over—validating the submission, recalculating duties, and ultimately generating the refund.
CBP’s official CAPE filing instructions are available here.
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While the process may sound straightforward, CAPE validation rules are strict:
Multiple screening layers ensure only eligible entries are processed.
Entries tied to reconciliation, drawback, USMCA duty deferral, open protests, or AD/CVD may be rejected.
Entries more than 80 days past liquidation are excluded.
Submissions are not fully rejected—only ineligible entries are removed.
Detailed feedback is provided for correction and resubmission.
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Once a CAPE Declaration is accepted, the system performs “mass processing”:
IEEPA-related Chapter 99 tariff lines are removed from each entry
Duties are recalculated as if those tariffs were never applied
Refund amounts are calculated automatically
Interest is applied in accordance with standard CBP refund rules
Enables large-scale, automated processing instead of manual corrections
Timing and Refund Expectations
CBP has outlined a relatively defined timeline for refunds under CAPE:
Unliquidated entries will generally liquidate 45 days after CAPE acceptance
Liquidated (non-final) entries may reliquidate as early as the next business day
Refunds are expected within 60 to 90 days of submission
Refunds themselves will not be issued entry-by-entry. Instead, CBP will consolidate them into lump-sum payments, grouped by importer and liquidation date, and disbursed via ACH.
For importers, that means one critical prerequisite
ACH enrollment is mandatory to receive funds without delay.
Strategy Matters More Than Ever
Despite the efficiencies CAPE introduces, this is not a purely mechanical process. In fact, the rollout introduces a new layer of strategic decision-making for importers.
For example:
Protests filed solely for IEEPA refunds may be better withdrawn and rerouted through CAPE.
PSCs cannot be used to request IEEPA refunds and must be handled separately.
Entries involving drawback or surety-paid duties require careful coordination.
Filing order matters—CAPE submissions should precede drawback claims.
In short, while CAPE simplifies processing, it places greater emphasis on getting the submission right the first time.
A New Tool, But Not a Complete Solution—Yet
It’s important to note that this is only Phase 1 of CAPE. CBP has already indicated that additional functionality and guidance will follow, particularly as the agency works through edge cases and high-volume scenarios.
In the meantime, importers have access to new ACE reporting tools, including the REV-615 CAPE Refunds Trade Report, which provides visibility into refund activity as it progresses through the system.
Where Juno Customs Solutions Fits In
From a brokerage perspective, CAPE introduces a new category of service—one that sits somewhere between compliance review and data analytics.
While CBP has provided the framework, the responsibility for:
Identifying eligible entries,
Validating data accuracy, and
Preparing submission-ready files
falls squarely on the importer and their broker.
Juno Customs Solutions is supporting clients through the CAPE process by helping review data, prepare submissions, and ensure filings are as accurate and complete as possible for efficient refund processing.
As a general note, CAPE-related activities—such as data review, validation, and submission preparation—fall outside the scope of standard entry services and may be handled as a separate, dedicated service depending on the level of support requested.
Feel free to contact us at brokerage@junocustoms.com or to your client representative to discuss CAPE, services provided and for a quote.