Trade Advisory Update

CBP Outlines CAPE Process for IEEPA Tariff Refunds

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The U.S. Court of International Trade has shifted the IEEPA tariff matter from legal review to operational execution. Following the Court’s March 4–5, 2026 orders directing the removal of IEEPA tariffs, U.S. Customs and Border Protection (CBP) has been authorized to proceed with a structured implementation approach for administering refunds.

On March 12, 2026, CBP filed a detailed declaration describing how it intends to process IEEPA tariff refunds through a new system within the Automated Commercial Environment (ACE) called Consolidated Administration and Processing of Entries (CAPE). The Court has accepted this framework as the path forward for implementation. The Court’s underlying ruling that IEEPA tariffs are unlawful remains unchanged.

How the CAPE Process Will Work

CBP has designed CAPE to manage refunds in an automated, scalable manner. The process consists of four integrated steps:

• CAPE Claim Portal – Importers or brokers will submit refund requests through a new web‑based portal in ACE by uploading a CSV file listing eligible entry summaries. Submissions will be validated automatically, and errors can be corrected and resubmitted.
• Mass Processing – Once validated, CAPE will remove IEEPA Chapter 99 HTS numbers and recalculate duties as if IEEPA tariffs were never applied.
• Review and Liquidation / Reliquidation – Entries will be scheduled for liquidation or reliquidation, interest will be calculated automatically, and CBP may conduct targeted reviews where needed.
• Refund Issuance – Refunds will be consolidated by importer and liquidation date and issued electronically through the U.S. Treasury. CBP has indicated CAPE will be deployed in phases, with the initial rollout covering most formal and informal entries, subject to certain exclusions. Additional functionality and guidance will be released over time.

What This Means for Importers

Refunds will be processed only through CAPE, will be electronic, and will not be immediate. Importer or broker participation through the CAPE Claim Portal will be required, and refunds will be issued on a staged basis as system functionality comes online.

Looking Ahead

Attention has now shifted to how refunds will be carried out in practice. Although the Court has approved CBP’s CAPE framework as the path forward, CBP has confirmed that refunds will not be processed until formal guidance is released and the necessary systems are fully in place. Importers are encouraged to hold off on submitting claims for now and instead focus on preparation—such as reviewing impacted entries, verifying liquidation status, confirming electronic refund setup, and coordinating with brokers—so filings can be made efficiently once CBP opens the process.

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.