Apr 29, 2026
CAPE Online Portal: How US Importers Can Actually Get Their IEEPA Refunds
To recover IEEPA duties paid over the past several years, you now file a consolidated refund claim through the Consolidated Administration and Processing of Entries (CAPE) module inside CBP's ACE Secure Data Portal, which went live in Phase 1 on April 20, 2026.
Phase 1 covers unliquidated entries plus most liquidated entries filed within the last 80 days, and typical refunds arrive 60 to 90 days after a clean declaration is accepted. You will need ACE Portal access, current ACH banking details, and a reconciled list of entry summaries before you touch the portal. Expect several hours of prep per broker relationship.
What Is CAPE and How Does It Work
CAPE is the sole intake mechanism CBP has built to process mass refunds of IEEPA tariffs after the Supreme Court ruling struck down the underlying tariff authority in February 2026. Rather than forcing importers into entry-by-entry protests, the system lets the importer of record or their licensed customs broker upload a CSV listing thousands of entry summaries at once. CBP then recalculates duties as if IEEPA never applied, liquidates or reliquidates the entries, and issues a consolidated ACH refund per importer and liquidation date.
More than 53 million entries and roughly 330,000 US importers of record paid IEEPA duties, and the Wharton Budget Model projects refund exposure could reach $175 billion. A volume that large made entry-by-entry processing logistically impossible, which is why CBP needed a new consolidated tool. The CIT ordered CBP to refund duties across all affected importers of record, not only named plaintiffs, and CAPE is the agency's answer to delivering on that order at scale. The statutory authority for Phase 1 reliquidations sits in 19 U.S.C. § 1501, which allowed CBP to act without requiring fresh court orders.
Refunds are not automatic. You or your broker must affirmatively submit a CAPE Declaration. Phase 1 is expected to capture roughly 63% of IEEPA-impacted entries. The remainder will require later phases, protests, or other remedies.
What Phase 1 Covers
Phase 1 includes four categories of entries:
Unliquidated entries where IEEPA duties were paid or deposited
Entries liquidated within 80 days of filing a CAPE Declaration, aligning with CBP's 90-day voluntary reliquidation window minus a 10-day processing buffer — widely referred to as the 80-day cliff across trade advisories
Entries with liquidation status marked Suspended, Extended, or Under Review, including certain AD/CVD entries that remain suspended pending Commerce instructions
Warehouse and warehouse-withdrawal entries, which receive IEEPA adjustments in CAPE but refund through the normal liquidation cycle
Phase 1 excludes the following categories, which require a protest under 19 CFR Part 174, a later CAPE phase, or another remedy:
Finally, liquidated entries beyond the 90-day reliquidation window
Entries flagged for reconciliation
Entries subject to drawback claims
Entries with an open protest
Entries not filed in ACE
AD/CVD entries where Commerce has already issued liquidation instructions
How to File a CAPE Declaration
Most rejected claims fail before anyone opens the portal. Prepare the following before you touch CAPE:
ACE Portal access for the importer of record
Only the IOR and licensed customs brokers with appropriate ACE filer authority can submit a CAPE Declaration. Third-party consultants without filer privileges cannot submit on your behalf.
Enrollment in ACH refunds with current banking details
CBP pays all refunds electronically. The agency has reported tens of thousands of rejected refunds in other contexts because recipients never added valid bank information. Treat ACH readiness as non-negotiable before anything else.
A complete, reconciled list of IEEPA-affected entry summaries
Pull ACE reports covering the full IEEPA period, confirm which entries carry the relevant Chapter 99 HTS codes, and cross-check that records from multiple brokers line up.
A decision on who files
Many importers have several brokers. Choose which party prepares each declaration and how you will share data before filing begins. Declarations cannot be amended after acceptance, so ownership and data responsibility must be agreed in advance.
Counsel review of the declaration acknowledgments
CAPE's declaration includes language that may permit CBP to offset refunds against other government debts. Have someone who understands your full liability picture read it before you click submit.
If any of these items are missing, fix them before touching CAPE. The system rejects submissions at the declaration level, not only the entry level, so one bad row can kill thousands.
The Six-Step Filing Process
The CAPE workflow is a CSV upload wrapped in portal validations. The clicks are short. The prep is long.
Step 1: Log into the ACE Secure Data Portal and open CAPE
Sign in to ACE with your existing portal credentials. Once inside, locate the CAPE tab or module on your IOR dashboard. If the tab is not visible, your account lacks CAPE filer privileges, and you need to work with CBP or your broker to update ACE roles before continuing.
Expected result: you see the CAPE Claim Portal landing page with an option to start a new Declaration.
Step 2: Build and scrub your entry list
Export every entry summary where IEEPA duties were paid or deposited, using ACE reports for the full lookback window. Remove entries that Phase 1 explicitly excludes:
Reconciliation entries (Type 09)
Drawback entries
Entries with open protests
Entries not filed in ACE
AD/CVD entries with pending Commerce liquidation instructions
For each liquidated entry, calculate days since liquidation against today's date. Any entry past 80 days is outside the CAPE window and needs to move to the protest track. Run this date calculation on a weekly cadence so borderline entries do not slip past the cliff unnoticed.
Running an internal pre-filing review of your historical entry population is worth doing at this stage. The same entries that drive refunds can reveal unrelated classification, valuation, or origin errors that CBP's five-year lookback would surface. Identifying those in-house, with documentation prepared in advance, is considerably better than having them surface through a CBP compliance review of your CAPE data.
Expected result: a clean spreadsheet grouped by IOR and refund recipient, with fewer than 10,000 rows per planned declaration.
Step 3: Format the CSV to match the CAPE template
Download the CAPE Declaration CSV template from the portal and map your entry list into the required column structure, including entry numbers, ports, filer codes, and any other fields CBP specifies. The most common causes of validation failure are:
Stray characters in data fields
Merged cells carried over from spreadsheet formatting
Text-formatted numeric fields that should be numeric data types
A single CAPE Declaration can cover up to 9,999 entries grouped by importer of record and refund recipient. Treat the CSV build as a data engineering task, not a copy-paste exercise.
Expected result: a CSV file that opens cleanly, has no blank rows, and matches the template column order exactly.
Step 4: Upload the CSV and work through validation errors
Upload the file through the CAPE Claim Portal. The system validates formatting, filer authorization, liquidation status, and eligibility against ACE records in real time. If any row fails, expect the whole declaration to reject. Correct the flagged rows in your source spreadsheet, regenerate the CSV, and resubmit.
Expected result: the portal accepts the declaration and issues a confirmation number you can use for tracking.
Step 5: Acknowledge declaration terms and submit
Review the declaration-level acknowledgments, including any language permitting CBP to offset refunds against other federal debts owed by the importer. Once submitted, the declaration cannot be amended. Newly discovered entries require a new declaration filed subject to the same 80-day cliff and Phase 1 scope rules.
Expected result: CAPE moves the declaration into its review queue and the ACE Collections pipeline begins scheduling entries for liquidation or reliquidation.
Step 6: Monitor processing through ACE reports
Pull CBP's CAPE-specific refund reports, referred to in advisories as REV-615, from ACE on a weekly cadence to reconcile accepted declarations against actual refunds paid. Track liquidation dates on entries that slipped past the 80-day window so they can be protested within the 180-day statutory period.
Expected result: you know, entry by entry, which refunds have landed, which are still in review, and which need to be re-routed to the protest track.
Timelines, Mistakes, and What to Do When Things Go Wrong
How Long CAPE Refunds Take
CBP has told the CIT it may take up to 45 days from declaration acceptance to complete review and liquidation or reliquidation of validated entries. Once liquidated, refunds including statutory interest should land in the importer's designated ACH account within roughly 60 to 90 days of declaration acceptance, assuming no compliance flags.
Timelines stretch for certain entry statuses. Warehouse entries, entries with liquidation suspended for AD/CVD reasons, and entries under extended or under-review status can be stripped of IEEPA HTS lines inside CAPE but will not generate cash refunds until the underlying entries liquidate through normal ACE processes. A clean CAPE submission does not guarantee a fast payment if the entry cannot yet liquidate.
CBP also retains discretion to flag entries for compliance review. The most likely triggers for extra scrutiny are:
Large refund amounts that exceed typical account history
Mismatches between ACE records and CAPE submission data
Entries intertwined with AD/CVD complexity
Each flag can add several weeks to the timeline.
Mistakes That Derail CAPE Claims
Early portal traffic shows the same failure patterns repeating. Address these before filing rather than after.
1. Submitting without ACH setup
Refunds sit in limbo when the recipient has not enrolled for ACH in ACE or has outdated bank details on file. Confirm banking with your treasury team before the declaration goes in.
2. Mixing ineligible entries into a single CSV
Reconciliation, drawback, and open-protest entries will trigger declaration-level rejection. Segment your entry population in advance and file separate declarations for cleanly-eligible rows.
3. Missing the 80-day cliff on liquidated entries
Entries liquidated more than 80 days ago are rejected by CAPE. Run the date math weekly so you do not lose the simplified track on borderline entries.
4. Uploading a raw ACE export
CAPE's validation is strict about column order, field types, and formatting. Treat the CSV build as a data engineering task and test with a small declaration before attempting the full population.
5. Over-relying on a single broker
Importers with multiple customs brokers often find duplicate, missing, or inconsistent entries across broker systems. Reconcile a single source-of-truth entry list across all brokers before anyone files.
6. Ignoring downstream exposure
A refund claim spotlights historical entries, which can surface unrelated classification, valuation, or origin errors inside CBP's five-year lookback. Surfacing those in-house, with documentation prepared before CBP sees them, is considerably better than having them surface through a compliance review of your CAPE data.
What to Do When the Portal Is Slow or Throws Errors
Early launch coverage reported high-volume error messages and ACE account issues such as duplicate tax ID conflicts blocking access entirely. When the portal is overloaded, try off-peak windows in the early morning or later in the evening rather than retrying continuously during business hours.
If the blocker is an ACE account conflict rather than portal load, open a support case with CBP rather than waiting. These tend to require human resolution and can take days.
Do not wait until the 80-day window is almost closed to file on borderline liquidated entries. Use a staged approach. Submit a small test declaration first, resolve any account or data issues surfaced by that run, and then scale up to full-population declarations. Build a buffer into your filing calendar and treat the test run as a mandatory step, not an optional one.
Your Five-Stage Action Plan
The fastest path from eligibility to refund follows five stages in sequence:
Scope: Map the full universe of IEEPA-affected entries against ACE records for the entire lookback period. Identify the IOR, entry type, and liquidation status for every entry before opening the portal.
Scrub: Review that universe for data quality. Flag exclusions (reconciliation, drawback, open protests, non-ACE entries, AD/CVD with pending Commerce instructions) and remove them before filing. Identify entries past the 80-day cliff that need to move to the protest track immediately.
Segment: Divide your entry population into three groups: Phase 1 candidates ready for CAPE, protest-track candidates that need a 19 CFR Part 174 filing within 180 days of liquidation, and deferred entries to be addressed in later CAPE phases.
Submit: File declarations in staged batches starting with a small test declaration. Resolve any account, formatting, or eligibility issues surfaced by the test run before scaling to full-population submissions.
Monitor: Pull REV-615 reports from ACE weekly. Track which refunds have landed, which are still in review, and which need to be re-routed. Monitor CSMS bulletins for CBP announcements on later phases that could reopen excluded entry categories.
Wrap the refund project inside a broader compliance review. The entries that drive refunds are the same ones CBP will examine if it conducts a compliance review of your CAPE submission. Reviewing classification, valuation, and origin accuracy across your historical entry population before filing is not optional risk management; it is the difference between a refund project and a refund project that triggers an audit.
Before you submit, validate your data. Gaia's Tariff Audit flags classification, valuation, and origin errors in your entry population before CBP sees them, so your CAPE declaration goes in clean. Run your audit now →
Frequently Asked Questions
Is the CAPE online portal mandatory to get my IEEPA refund?
For most Phase 1 entries, yes. CBP has built CAPE as the sole intake mechanism for consolidated IEEPA refund claims inside ACE, with no parallel paper or ABI path. Entries excluded from Phase 1, those finally liquidated beyond the 90-day window, reconciliation-flagged entries, drawback entries, and entries with open protests, still require a protest under 19 CFR Part 174 or another remedy. There is no automatic refund to wait for.
Can I amend a CAPE Declaration after I submit it?
No. once accepted, a declaration cannot be edited or withdrawn. Additional eligible entries require a new declaration subject to the same 80-day cliff and Phase 1 scope rules, which is why filing a small test declaration first saves significant rework.
How long will my IEEPA refund take?
Expect 60 to 90 days for straightforward Phase 1 entries, based on CBP's guidance and a 45-day review window plus ACH disbursement time. Warehouse and AD/CVD entries with suspended liquidation take longer. Compliance flags on mismatched or unusually large entries can add several more weeks.
Do I still need a customs broker if I already have ACE access?
Most importers will. Brokers typically hold the cleanest entry data and can coordinate across multiple filer codes. In-house teams still own scoping, ACH setup, and counsel-level decisions on offsets. The workload splits rather than disappears.
