On April 20, 2026, at 8 a.m. EST, US Customs and Border Protection flipped the switch on CAPE — the Consolidated Administration and Processing of Entries portal — inside the ACE Secure Data Portal. Two months after the Supreme Court struck down IEEPA tariffs in V.O.S. Selections Inc. v. United States, importers can finally begin filing for refunds. The numbers are staggering: approximately $166 billion in IEEPA duties were collected from more than 330,000 importers across 53 million shipments between April 2025 and February 2026. As of April 14, 56,497 importers had already completed ACH registration and are eligible for refunds totaling $127 billion including interest. This guide walks you through the filing process step by step, covers Phase 1 qualification rules, and explains which duties do — and don't — get refunded.
What Happened: CAPE Portal Launches April 20, 2026
CBP launched the Consolidated Administration and Processing of Entries (CAPE) portal on April 20, 2026, at 8 a.m. EST. CAPE lives inside the ACE (Automated Commercial Environment) Secure Data Portal — the same system importers already use for entry filings. The launch follows the Supreme Court's February 20, 2026 ruling in V.O.S. Selections Inc. v. United States, which held 6-3 that IEEPA does not authorize tariffs. In March, the Court of International Trade ordered the administration to begin reimbursing importers. Total IEEPA duties collected from April 2025 through February 2026 add up to approximately $166 billion from over 330,000 importers across 53 million shipments. As of April 14, 56,497 importers had completed ACH (electronic funds transfer) registration — a prerequisite for refunds — and are eligible for a combined $127 billion in refunds including interest.
How to File for an IEEPA Refund (Step by Step)
The filing workflow runs entirely through the ACE Portal. Step 1: Register for an ACE Secure Data Portal account at ace.cbp.dhs.gov if you don't already have one. Step 2: Enroll in ACH for electronic refunds — this is required. CBP will not issue refund checks; payments must go to a US bank account via ACH. Step 3: Prepare a CAPE Declaration. This is a CSV file that lists every entry number you want refunded. Step 4: Log into ACE, navigate to the new CAPE tab, and upload your CAPE Declaration file. Step 5: Wait for CBP validation. CBP runs two rounds of checks — first at the declaration level (file formatting, importer identity, ACH status), then at the entry level (does each entry actually qualify, what rate applies, is it unliquidated or within the 80-day window). Step 6: Refunds issue via ACH within 60 to 90 days of declaration acceptance, including statutory interest calculated from the original entry date.
Who Qualifies for Phase 1
Phase 1 covers only two categories of entries: (1) unliquidated entries — entries CBP has not yet finalized, which is most entries from the last 10-12 months, and (2) entries that have been liquidated but are still within 80 days of liquidation, which is the statutory window for filing a protest under 19 U.S.C. § 1514. Older liquidated entries fall outside Phase 1 and will need to wait for later phases or be pursued directly through the Court of International Trade. Only the Importer of Record (IOR) — or a licensed customs broker filing on the IOR's behalf with a valid Power of Attorney — can file a CAPE Declaration. Each declaration can include up to 9,999 entries. Large importers can submit multiple declarations. But there's a hard rule: once a declaration is accepted, it cannot be amended, and any entry already on an accepted declaration cannot be submitted on another. Plan the grouping carefully.
What Gets Refunded (and What Doesn't)
CAPE Phase 1 refunds all duties paid under IEEPA authority — that is, the reciprocal tariffs that took effect April 5, 2025 and the adjusted country-specific rates that took effect August 1, 2025. That covers both the 10% baseline reciprocal tariff and all country-specific rates above 10% (Vietnam 46%, Thailand 36%, Taiwan 32%, South Korea 25%, EU 20%, the China 10% reciprocal + 10% fentanyl surcharge, and every other IEEPA rate). Refunds include statutory interest from the original entry date. What does NOT get refunded: Section 232 tariffs on steel (50%), aluminum (50%), autos (25%), copper (50%), semiconductors (25%), and lumber (10%) — these were imposed under national security authority and were not part of the SCOTUS ruling. Section 301 tariffs on China (25-100%, product-specific) also remain — imposed under separate trade law authority. And critically, the current 10% Section 122 tariff — Trump's replacement signed on February 20, 2026 — is NOT refundable. Section 122 is a different legal authority, still in force, and still being collected.
Key Warnings for Importers Filing in Phase 1
The CAPE process is unforgiving about errors. Warning #1: If any entry on your CAPE Declaration doesn't qualify — wrong entry type, already liquidated beyond 80 days, not actually IEEPA-paid — CBP may reject the ENTIRE declaration, not just the bad line. Double-check every entry number before submitting. Warning #2: You cannot amend a declaration after submission. If you left entries off, file a second declaration for those, but you can't fix an accepted one. Warning #3: Entries already on an accepted declaration cannot be resubmitted. One shot per entry. Warning #4: Phase 1 only covers unliquidated entries and entries within 80 days of liquidation. Older entries — particularly those from April through August 2025 that have already liquidated and passed the protest window — will need to wait for later CAPE phases or be pursued through the Court of International Trade. Warning #5: The administration has publicly hinted it may try to offset refund amounts using alternative tariff authorities or claw back portions of what's owed. Treasury Secretary Bessent predicted the process 'could be a mess' lasting months or years. File promptly and document everything. Warning #6: Some importers will fall into gaps CAPE doesn't cover — for them, a CIT filing with legal representation is the realistic path.
Do You Need a Customs Broker?
Legally, no — an Importer of Record can file a CAPE Declaration directly through ACE. Practically, if you import at any scale, use your broker. Brokers already have your entry data, already filed the original 7501 entries that paid the IEEPA duty, and already know the rejection patterns that trip up first-time filers. For an importer with hundreds or thousands of entries across the 10-month IEEPA window, broker automation is the difference between filing one well-formed CSV and manually reconciling entry numbers for weeks. Fees vary — expect per-entry CAPE filing fees on top of original brokerage, though several large brokers (Livingston, Expeditors, CH Robinson) have announced flat-rate or capped CAPE pricing for existing customers. If you have 10 or fewer entries, self-filing through ACE is feasible. If you have hundreds, delegate.
How Long Until You Get Paid
CBP's stated processing time is 60 to 90 days after a CAPE Declaration is accepted. 'Accepted' means it passed both validation rounds — declaration-level and entry-level — which itself can take 2-4 weeks after submission during the initial launch surge. Realistic expectation for an importer filing a clean declaration in late April 2026: funds arrive via ACH somewhere between mid-July and mid-August. Rejected declarations reset the clock — if CBP bounces your file for a single bad entry, you pull that entry, resubmit the declaration, and the 60-90 day window restarts from the new acceptance date. Because of the surge and the administration's hinted resistance, Treasury Secretary Bessent has publicly warned the process 'could be a mess' and may extend longer than CBP's stated timelines. Plan cash flow assuming Q3 or Q4 2026, not 'by June.'
Will Consumers Get Refunds?
Short answer: no, not directly. Refunds under CAPE go to the Importer of Record — the company that paid customs duty at the port of entry. Consumers paid those tariffs indirectly, embedded in higher wholesale and retail prices, but they have no direct claim on CBP. A handful of companies have publicly pledged to pass refunds along: FedEx has stated it will credit affected shipping customers on a best-effort basis, and Costco has mentioned passing savings through to member pricing. Most retailers paid tariffs indirectly through higher wholesale costs from importer-distributors, and few have committed to any pass-through. Several class-action lawsuits have been filed against Costco, FedEx, and others by consumers seeking direct refunds. Those cases will take years. Realistically, most US consumers will not see a direct refund — the $166 billion flows back to importers, and how much reaches end customers depends on each company's pricing decisions. Downstream effects will show up in 2026-2027 retail prices, not in refund checks.
What About Phase 2 and Later Entries?
Phase 1 is intentionally narrow — it covers the cleanest cases (unliquidated entries and recent liquidations) to get money moving fast. CBP has indicated Phase 2 will extend to older liquidated entries, but no launch date has been announced. Expect guidance in summer 2026. Entries that fall entirely outside CAPE — for example, very old liquidations or complex cases with surety disputes — will likely need to be pursued through the Court of International Trade with legal representation. If you have significant entries from April through August 2025 that have already liquidated and passed the 80-day protest window, start preparing now: pull all your 7501s, payment records, and liquidation notices. When Phase 2 opens, the importers with organized records will file first and get paid first.
What to Do Right Now (Action Checklist)
Step 1: Confirm ACE Secure Data Portal access. If you're an IOR and don't have an account, register today. Step 2: Enroll in ACH for electronic refunds — without this, nothing moves. Step 3: Pull a list of every entry you filed between April 5, 2025 and February 24, 2026 that paid IEEPA duty. Sort by liquidation status. Step 4: Identify which entries qualify for Phase 1 (unliquidated or within 80 days of liquidation). Step 5: Contact your customs broker. If they have a CAPE filing service, get on their queue early — the launch week surge will bottleneck processing. Step 6: For entries outside Phase 1, preserve all documentation (7501, proof of payment, liquidation notice) and wait for Phase 2 guidance. Step 7: Do not rely on the current Section 122 10% tariff being refunded — it's a different legal authority and not part of this proceeding. Step 8: Subscribe to CBP's IEEPA refund email list for Phase 2 announcements and rule changes.
Key Takeaway
The CAPE portal is the fastest legal path to IEEPA refunds for most importers — but Phase 1 only covers unliquidated entries and entries within 80 days of liquidation, and the rules are unforgiving. File clean declarations, double-check every entry number, and expect 60-90 days from acceptance to ACH deposit. Section 232, Section 301, and the current 10% Section 122 tariff are all excluded from refunds. If you have older entries outside Phase 1, preserve documentation and prepare for Phase 2 or a CIT filing. Use our refund estimator to see roughly how much you're owed, then get your ACE account and ACH enrollment squared away today.
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