Trade Advisory: CBP IEEPA Update

CBP IEEPA Duty Refund Webpage & CAPE FAQs

April 10, 2026

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U.S. Customs and Border Protection (CBP) has launched a dedicated public webpage to consolidate official guidance related to the refund of duties imposed under the International Emergency Economic Powers Act (IEEPA). While the page includes Frequently Asked Questions (FAQs), CBP has positioned this rollout as a centralized information hub explaining how affected entries will be administered, corrected, and refunded through the Consolidated Administration and Processing of Entries (CAPE) framework within the Automated Commercial Environment (ACE).

This webpage supplements prior court filings and CSMS guidance by providing CBP’s current operational posture and clarifying eligibility parameters, system limitations, and administrative constraints associated with CAPE-based refunds.

Importer of Record Requirement

Only the importer of record (IOR) identified on the customs entry is entitled to request and receive IEEPA duty refunds through CAPE. CBP does not evaluate contractual cost pass-throughs, reimbursement arrangements, or downstream economic burden when determining refund eligibility.

Scope of Duties Eligible for Refund

Refunds apply solely to additional duties assessed under IEEPA-specific HTS provisions. CAPE will not recalculate base HTS duty rates, fees, or duties imposed under other statutory authorities.

Liquidation Status Drives Processing

CBP reiterates that CAPE processing is being implemented in phases. Phase 1 prioritizes unliquidated entries and entries still within the voluntary reliquidation window. Entries with final liquidation will be addressed in later CAPE phases pursuant to Court of International Trade orders.

Refund Timing and Liquidation Mechanics

IEEPA HTS provisions will be removed, and duties recalculated as if IEEPA never applied; however, refunds generally will not be issued until liquidation or reliquidation occurs in the normal course. Submission of a CAPE Declaration does not accelerate liquidation.

Electronic Refund Enrollment

Electronic refund enrollment through ACH within ACE is mandatory. CBP will not issue paper checks, and refunds will not be released until enrollment is complete.

Excluded Entry Types

Entries subject to reconciliation, drawback claims, open protests, not filed in ACE, or certain AD/CVD entries are excluded from CAPE Phase 1 and will be addressed in later phases.

Disclaimer

CBP guidance published on its IEEPA Duty Refund webpage is administrative and informational in nature and does not constitute certification of eligibility, advance determination, or guarantee of refund timing or amount. Refunds remain subject to CBP validation, liquidation status, system constraints, and judicial orders. Crane Worldwide Logistics does not certify refund eligibility or outcomes and relies on information provided by the importer of record.

If IEEPA duty refunds or CAPE processing may impact your organization, our Trade Consulting team is ready to support you. We can provide guidance on refund eligibility assessments, liquidation status review, CAPE declaration planning, and CBP compliance considerations as guidance continues to evolve. Reach out to us via our Tariff Response Unit now!