US CBP IEEPA Duty Refunds: CAPE System Update

Following the US Court of International Trade (CIT) decision on duties collected under the IEEPA, for which the US President Donald Trump was not authorized to impose, the US Customs and Border Protection (CBP) was directed to refund them and correct millions of import entries affected by those tariffs. On March 31, 2026, the CBP informed the CIT that its new CAPE system within the Automated Commercial Environment (ACE) is making significant progress in calculating and refunding duties.
Refund of Duties and Actions Businesses Should Take
CAPEs Phase 1 will initially process unliquidated entries and those liquidated within the prior 80 days, covering about 63% of entries with IEEPA duties, allowing reliquidation within the 90-day statutory window. The CBP explained how the recalculation and refund process works, depending on the status and type of entry, including whether it is under review, suspended, subject to AD/CVD instructions, or a warehouse entry, with certain entries excluded from Phase 1 and refunds deferred until normal liquidation procedures apply.
Entries excluded by the Phase 1 include reconciliation entries, drawback claims, open protests, entries not in ACE or lacking liquidation status, and AD/CVD entries awaiting liquidation instructions. The CBP anticipates that it will take up to 45 days to review and liquidate validated entries after CAPE declaration acceptance. Other CAPE phases will expand functionality to handle more complex cases, including reconciliation and drawback entries, final liquidations, non-ABI entries, and advanced interest calculations.
Businesses should take several preparatory steps for Phase 1, depending on their circumstances. Some steps to consider include segmenting IEEPA-affected entries into unliquidated, recently liquidated, and excluded or complex categories to plan submissions and determine which entries should be deferred to a later phase. Furthermore, compiling entry summaries, verifying ACE status, and checking for IEEPA Chapter 99 HTS codes to minimize validation errors is essential for preparing CAPE Declarations.
Conclusion
The CBP reported that the Claim Portal is about 85% complete, that around 80% of the liquidation/reliquidation functionality is complete, and that refund processing is at 75%. Given that the electronic refunds are mandatory for all IEEPA refunds, 26,664 importers of record have completed the setup, covering roughly 78% of affected entries and representing about USD 120 billion in principal.
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