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U.S. Customs IEEPA Duty Refunds: The CAPE System

As of March 2026, U.S. Customs and Border Protection (CBP) is finalizing a new system within the Automated Commercial Environment (ACE) portal to manage IEEPA duty refunds. Known as the Consolidated Administration and Processing of Entries (CAPE), this framework automates the lifecycle of a refund through a four-step architecture:

  • ■ Claim Portal: A new tab will appear in the ACE Portal. Filers will submit "CAPE Declarations" by uploading a CSV file of eligible entry summaries. The system performs strict file-level and entry-level validations to confirm IEEPA HTS Chapter 99 designations.
  • ■ Mass Processing: Validated entries are processed to automatically strip IEEPA-specific HTS numbers. Duties are recalculated as if the IEEPA charges were never assessed.
  • ■ Review & Reliquidation: Entries are scheduled for liquidation or reliquidation after a set timeframe, allowing a window for manual CBP review and automatically calculating any interest owed.
  • ■ Automated Refund: Once liquidated, entries are routed to a CAPE-specific workflow in the ACE Collections module. Refunds are consolidated by the liquidation date and Importer of Record (IOR) and issued via electronic payment.

Importer Readiness & Current Status

While the CAPE system components are currently in development (estimated at 40%–80% complete as of mid-March 2026), proactive preparation is critical to ensure seamless refund processing.

Action Required for ACE Portal Refund Readiness:

  • Enroll in ACH Refunds: Effective February 6, 2026, CBP transitioned to an all-electronic refund system and no longer issues paper checks. Importers must have an active ACE Portal account and be enrolled in the Automated Clearing House (ACH) Refund program.
  • Verify ACE Access: Ensure you have "Importer Sub-account" access in the Modernized ACE Portal to view the "ACH Refund Authorization" tab and the forthcoming CAPE tab.
  • Identify Eligible Entries: Utilize the Entry Summary details report (ES-003) in ACE to identify entries containing IEEPA HTS codes (e.g., 9903.01.XX and 9903.02.XX).

Recent Guidance:

  • Phased Rollout: Phase 1 targets standard formal and informal entries. Initial exclusions include unliquidated AD/CVD entries, warehouse withdrawals, and entries in "Suspended" or "Under Review" status.
  • Timeline: CBP is operating under a court order to provide regular progress reports, with the next critical update due by March 19, 2026.

Note: For deeper background on the court ruling, reference updates from KPMG or V. Alexander & Co.

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