What is the purpose of Customs CAPE update in ACE?

Consolidated Administration and Processing of Entries (CAPE) is being developed to calculate and provide valid refunds of additional ad valorem duties imposed under IEEPA. In plain English, U.S. Customs & Border Protection (CBP) is building a structured Automated Commercial Environment (ACE) workflow so importers and brokers can identify affected entries, have the International Emergency Economic Powers Act (IEEPA) duty element(s) stripped out, and move those entries through liquidation or reliquidation so refunds can be issued correctly.

NOTE: CBP’s CAPE process is not final, nor has the Court of International Trade (CIT) agreed to the final process proposed by CBP.

CBP’s current design has four integrated components (complete % as of 3/30/2026):

Claim Portal: 85% complete
Mass Processing: 60% complete
Review and Liquidation/Reliquidation: 80% complete
Refund: 75% complete

How Phase 1 is expected to work

The front end appears to be a CAPE Declaration submitted through ACE by the importer of record or an authorized broker. CBP has described this as a portal-based process in which the filer uploads a CSV file identifying affected entry summaries. ACE then validates the filing and routes the entries into the automated recalculation workflow.

Once the declaration is accepted, the Mass Processing component is expected to:

Remove the IEEPA-related HTS indicator/code requirement from the selected entries.
Recalculate duty liability without the IEEPA duties.

From there, entries will move through CBP’s standard workflow, including:

Review
Liquidation/reliquidation path
Refund issuance

CBP also said it expects Phase 1 to cover about 63% of entries for which IEEPA duties were paid or deposited. This limitation is due to the initial system build only supporting a narrower range of entry-status scenarios.

What entries Phase 1 covers:

Still unliquidated, or
Within the 90-day voluntary reliquidation window under 19 U.S.C. § 1501.

Expanded Phase 1 Scope

CBP has further expanded the scope of Phase 1 beyond its initial description.

Phase 1 will now accept CAPE Declarations for entries with the following statuses:
- Suspended
- Extended
- Under Review
For these entries, CAPE will:
- Remove the IEEPA duty component
- Recalculate duties accordingly
However, refunds may not be issued immediately. In most cases, refunds will be processed once the entry liquidates through the normal course.
Phase 1 now also includes:
- Warehouse entries
- Warehouse withdrawals
Similar to other entries:
- CAPE will recalculate duties without IEEPA
- Liquidation will still occur under standard timelines
- Refunds will be issued once the entry is ready for liquidation
Certain AD/CVD entries may also be included in Phase 1, specifically where liquidation remains suspended pending instructions from Commerce.
For these entries:
- CAPE can remove the IEEPA duty portion
- CBP will not liquidate or issue refunds until the suspension is lifted
- Refunds will follow once liquidation is allowed to proceed

What Phase 1 does not cover

CBP says the following categories will not be accepted on a CAPE Declaration in Phase 1:

Entries flagged for reconciliation, including entry type 09.
Entries on a drawback claim.
Entries covered by an open protest.
Entries not filed in ACE, or entries without a liquidation status in ACE.
Certain AD/CVD entries where Commerce has already issued liquidation instructions and the entries are pending liquidation under 19 U.S.C. § 1504(d).

Timing under the current plan

CBP has indicated that, once a CAPE Declaration is accepted, it may take up to 45 days to review and liquidate the validated entries. This timeline may be extended if additional review is required due to compliance concerns.

CBP also noted that Phase 1 will accept entries liquidated within the prior 80 days. This allows the agency to complete processing and reliquidate those entries within the 90-day window under §1501.

What This Means in Practice

The 45-day timeframe does not mean that refunds will be issued within that period.

It means CBP is aiming for that review/liquidation cycle once the declaration is accepted and the entry falls inside the Phase 1 rules.

The actual timing of refunds will depend on:

The status of the entry
Whether liquidation can occur immediately or must follow the normal course

As a result, some refunds may be issued within this window, while others may take longer depending on the entry’s specific circumstances.

Refund mechanics and prerequisites

CBP’s refund component is built around electronic refunds, not paper checks. CBP’s interim final rule published on January 2, 2026 made electronic refunds the default, effective February 6, 2026, subject to limited exceptions.

If you need more information on the ACH Refund Process, please see our previous post. If an importer wishes to receive their IEEPA refunds timely, make sure the ACH Refund Process has been completed.

CBP says refunds can be issued to the importer of record or to a party designated on CBP Form 4811.

CBP reported that as of March 26, 2026, 26, 664 importers of record had completed the electronic-refund setup process, and those importers accounted for 78% of entries with IEEPA duty payments or deposits, representing about $120 billion in principal IEEPA duty payments/deposits.

That last point matters a lot: finally liquidated entries are not part of current Phase 1, but CBP says it intends to build that capability in a later phase. So the “current CAPE plan” is really a phased implementation, not a one-shot solution for every IEEPA refund scenario.

Our team will release additional information, including our plan to assist importers with their IEEPA refunds as more official information is released.

Need Assistance?

Juno Customs Solutions can assist with:

Entry review and refund exposure analysis
Protest filings (where applicable)
Documentation preparation
Ongoing regulatory updates

Contact us today at brokerage@junocustoms.com

Consolidated Administration and Processing of Entries - Factsheet