Trade Advisory Update

CBP CAPE Development Progress (IEEPA Refunds)

Latest

U.S. Customs and Border Protection (CBP) has submitted a second sworn declaration to the U.S. Court of International Trade providing an updated status on the development of the Consolidated Administration and Processing of Entries (CAPE) system within the Automated Commercial Environment (ACE). CAPE is intended to support the administration and refund of additional ad valorem duties imposed under the International Emergency Economic Powers Act (IEEPA). The declaration confirms continued system development and testing, but reiterates that CAPE is not yet operational and is not available for importer use.

CAPE Component-Level Status (as of March 19, 2026)

• Claim Portal – 73% complete: Substantially developed and undergoing multiple rounds of testing prior to deployment in the live ACE environment.
• Mass Processing – 45% complete: Development focused on ACE validations and event history tracking to ensure automated processing integrity and auditability; testing to begin imminently.
• Review and Liquidation / Reliquidation – 80% complete: Liquidation and reliquidation functionality is in testing, with further progress dependent on integration with other CAPE components.
• Refund – 63% complete: CAPE-specific refund functionality has been developed within the ACE Collections framework, including consolidation of refunds by liquidation or reliquidation date and importer of record (or designated payee).

What This Means for Importers

The proceedings have now moved beyond questions of legal authority and are focused on operational execution and system readiness. While the Court has accepted CBP’s CAPE-based framework, CBP has emphasized that additional development, validation, and testing must be completed before any refund mechanism is made available to the trade community. No claim filing procedures, timelines, or implementation guidance have been issued.

Next Steps

Importers should continue to monitor CBP and court-ordered updates, preserve entry, payment, and liquidation data that may be relevant to future refund processes, and refrain from initiating any IEEPA-related refund claims until CBP issues formal operational guidance.

This advisory is provided for general informational purposes only and does not constitute legal advice.

Need support navigating this development?

Our trade and customs specialists are actively monitoring CBP guidance and can assist with entry reviews, refund readiness, and coordination with brokers as implementation unfolds. Reach out to our Tariff Response Unit today.