On April 20, 2026, U.S. Customs and Border Protection ("CBP") will launch Phase 1 of its electronic tool for submission of requests for refunds of certain duties paid under the International Emergency Economic Powers Act ("IEEPA"). This tool—known as the Consolidated Administration and Processing of Entries ("CAPE") tool, found in CBP's Automated Commercial Environment Secure Data Portal ("ACE")—is limited, however, and will only extend to certain categories of duties paid under IEEPA, with later phases to cover other IEEPA-affected imports.
What Phase 1 covers. CBP states that Phase 1 will cover most entries that are unliquidated or up to eighty (80) days past liquidation. It also covers entries with a liquidation status of suspended, extended, or under review, as well as warehouse and warehouse withdrawal entries.
What a filer is required to submit and what happens next. For Phase 1, the filer must submit a CAPE Declaration, which is a comma separated values ("CSV") file uploaded through the CAPE tab in ACE that lists the entry numbers for which IEEPA duty refunds are requested. ACE will then run two sets of validations: first, it will validate the upload itself, including authorization and file formatting, and second, it will validate each entry number in the file against CBP records, including whether the entry exists in ACE and whether at least one dutiable IEEPA Harmonized Tariff Schedule ("HTS") Chapter 99 code was declared on the entry. If the file level checks fail, ACE will reject the CAPE Declaration. If individual entries fail entry-specific checks, ACE will reject those certain entries while continuing to process the remaining entries, and it will provide validation results so the filer can correct and resubmit as needed. For valid entries, ACE will update the entry summary lines to remove the dutiable IEEPA HTS Chapter 99 codes and duties and will recalculate duties without those codes. After CBP review, the entries will be liquidated or reliquidated as appropriate, and any refund will then be issued.
