April 1, 2026
U.S. Customs and Border Protection (CBP) has provided the Court of International Trade with an updated status report on its implementation of the court-ordered removal and refund of duties imposed under the International Emergency Economic Powers Act (IEEPA). This update provides additional detail on the readiness of CBP’s CAPE claim portal, clarifies how entries will be processed based on liquidation status, and explains which entry types are excluded from initial processing and when they are expected to be addressed.
CBP confirmed continued progress on each component of the Consolidated Administration and Processing of Entries (CAPE) system, which will be used to process IEEPA duty refunds.
The Claim Portal will serve as the sole intake mechanism for IEEPA refund requests. Importers or their authorized brokers must submit a CAPE Declaration identifying affected entries. CBP has completed most core development and is conducting final testing prior to deployment. Refunds will not be issued automatically.
The Mass Processing component handles bulk entry processing after claim submission. It removes IEEPA-related tariff provisions and recalculates duties as if IEEPA never applied. CBP has expanded its ability to adjudicate CAPE Declarations and modify entry summaries, with additional validation and tracking work ongoing.
This component governs CBP’s review controls and the timing of liquidation or reliquidation after CAPE processing. CBP is actively testing various liquidation scenarios. Final deployment is dependent on coordination with other CAPE components.
The Refund component issues electronic refunds through ACE once liquidation or reliquidation is complete. CBP has completed most Phase 1 development and is focused on testing and validation. Refunds will be issued electronically to the importer of record or a properly designated party.
The Court has directed CBP to treat all affected entries as if IEEPA duties never applied. CBP will implement this directive through a phased rollout of CAPE within the Automated Commercial Environment (ACE).
In the initial phase of CAPE, CBP will process:
For these entries, CAPE will remove IEEPA tariff provisions, recalculate duties, liquidate or reliquidate the entry, and issue refunds electronically following liquidation. CBP has indicated it may take up to 45 days from acceptance of a CAPE Declaration to complete review and liquidation, absent compliance concerns.
Phase 1 will also accept CAPE Declarations for entries with a liquidation status of suspended, extended, or under review, including entries subject to antidumping and countervailing duty (AD/CVD) suspension and warehouse or warehouse withdrawal entries.
For these entries, CAPE may remove the IEEPA tariff provisions and recalculate duties; however, liquidation and refund of IEEPA duties will occur later, once the entry liquidates in the normal course or suspension is lifted.
CBP confirmed that certain categories of entries will not be accepted in Phase 1 of CAPE and will be addressed in later phases. These include:
CBP has stated that these excluded entry types will be addressed in subsequent CAPE development phases. Later phases are expected to add functionality to process finally liquidated entries, reconciliation and drawback entries, complex interest calculations, and other higher-risk scenarios.
All IEEPA duties are ultimately required to be removed. However, CBP will process refunds in stages through CAPE. Phase 1 addresses unliquidated and recently liquidated entries, while excluded and finally liquidated entries will be addressed in later phases as CAPE functionality expands.
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.
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