The Complete CAPE Filing Guide: Step-by-Step IEEPA Refund Claim Submission
On April 20, 2026, US Customs and Border Protection activated the Consolidated Administration and Processing of Entries (CAPE) system in ACE — the portal through which 333,000+ importers can claim refunds of approximately $166 billion in IEEPA tariff duties invalidated by the Supreme Court's February 20, 2026 ruling in Learning Resources, Inc. v. Trump. This guide walks through the complete filing process, eligibility requirements, deadlines, and common rejection patterns from the first week of operation.
CAPE went live at 7:11am ET on April 20. By 8pm ET April 26, importers had submitted 75,306 declarations, of which 47,315 passed initial validation — a 63% success rate covering 11,222,927 entries. The other 37% bounced for fixable reasons. This guide is how you avoid being in that 37%.
Who Qualifies for Phase 1
CAPE Phase 1 covers approximately 63% of IEEPA-paid entries. Eligibility depends on liquidation status, not tariff classification or product type.
| Entry Status | Phase 1 Eligible? |
|---|---|
| Unliquidated entries | Yes |
| Liquidated within last 80 days | Yes — preserves the voluntary reliquidation window under 19 U.S.C. 1501 |
| Final liquidation entries (80+ days) | No — deferred to later CAPE phases |
The relevant entry-date range is roughly February 2025 through February 2026 — the period IEEPA-based duties were being collected before the Supreme Court invalidated the authority. If your entries fall in the Phase 1 buckets, file now. If they're in final liquidation, see the section below.
The Critical Deadlines
| Date | What it is |
|---|---|
| April 20, 2026 (7:11am ET) | CAPE Phase 1 went live |
| 80 days post-liquidation | Rolling cutoff — last day for Phase 1 eligibility |
| 90 days post-entry | Standard Post Summary Correction (PSC) window under 19 CFR 174 |
| 300 days post-entry | PSC outer limit |
| ~June 7, 2026 | Government's deadline to appeal Judge Eaton's refund order to the Federal Circuit |
| 60-90 days post-acceptance | Refund issued, absent compliance review issues |
The 80-day rolling deadline is the one that bites quietly. Every day, more entries cross from Phase 1 eligible into final liquidation. Prioritize by liquidation date, not entry date.
Step-by-Step Filing Process
1. Identify all IEEPA entries
Pull every entry filed between approximately February 2025 and February 2026 where IEEPA-based duties were paid. Your broker's ABI system has this. Filter by tariff program code or by HTS subheading impact. Don't rely on memory — pull the records.
2. Verify liquidation status of each
For every entry, determine: (a) unliquidated, (b) liquidated within the last 80 days, or (c) finally liquidated. Categories (a) and (b) go into the Phase 1 queue. Category (c) waits.
3. Calculate the IEEPA portion of duties paid
This is where most calculation errors happen. The IEEPA portion must be separated from Section 301, Section 232, and MFN base duties. Only the IEEPA component is refundable under CAPE Phase 1 — the other tariff programs were not invalidated by the Supreme Court ruling. If your product had stacked tariffs (e.g., MFN + Section 301 + IEEPA reciprocal), only the last layer comes back.
4. Prepare the CAPE Declaration package
Pull together: entry summary references, importer of record (IOR) information, tax ID, payment records. The most common rejection in week one was duplicate tax-ID errors — review IOR/consignee fields carefully. One typo turns into a rejected declaration.
5. Submit through ABI/ACE
CAPE Declarations file through your broker's ACE entry summary filer credentials. There is no direct-to-CBP filing path for importers without a broker.
6. Track validation status
Initial file validation passes or fails within hours. Full compliance review takes longer. ACE returns a status code; brokers should monitor and report status to clients in near-real time.
7. Respond to compliance requests
CBP may request supporting documentation — entry summaries, payment confirmations, IEEPA tariff calculations. Have these ready before you file. Compliance review delays are the single biggest cause of refund timeline slippage.
First-Week Lessons (April 20-26)
- 75,306 declarations submitted
- 47,315 passed initial validation (63%)
- 27,991 rejected (37%)
- 11,222,927 entries covered by validated declarations
The first 72 hours saw real portal congestion. Filers who waited until day three or four had cleaner runs. The 37% rejection rate is high but the errors are fixable on re-submission — none are fatal to the underlying refund right.
Common Rejection Errors and How to Fix Each
| Error Type | What It Means | How to Fix |
|---|---|---|
| Duplicate tax-ID | Same EIN/IOR appears on multiple declarations or in conflicting fields | Audit IOR vs. consignee fields, dedupe at the entry level before re-submitting |
| Mismatched IOR / consignee | The IOR on the CAPE Declaration doesn't match the IOR on the original entry | Pull the original entry summary; correct to match exactly |
| Portal congestion timeout | File submitted but timed out before validation | Re-submit during off-peak hours (early morning or late evening ET) |
| Cascade rejection | One bad entry in a batch fails the whole declaration | Split the batch, isolate the bad entry, re-file the clean ones |
| IEEPA amount mismatch | Calculated refund amount doesn't match CBP's records | Re-verify by separating IEEPA from Section 301/232/MFN; the IEEPA portion is what's refundable |
| Liquidation status error | Entry is past the 80-day window | Move to the Phase 2 queue when available — don't try to force it |
PSC vs. CAPE — Two Refund Paths
There are two paths to a refund, and most importers should use CAPE for IEEPA-specific claims.
| Mechanism | Window | Best Use |
|---|---|---|
| CAPE Declaration | While Phase 1 is open; rolling 80-day eligibility per entry | IEEPA-specific refunds. The dedicated mechanism. Use this. |
| Post Summary Correction (PSC) | Up to 300 days from entry date | Other entry corrections (classification, valuation, quantity). Useful as a backup if CAPE rejects an entry on technical grounds. |
PSC is the older, broader tool. CAPE is purpose-built for the IEEPA refund event. For a clean IEEPA refund claim, CAPE is the path. PSC remains relevant for non-IEEPA corrections that surface during the refund prep process.
What If You're in Final Liquidation (the 37%)
Roughly 37% of IEEPA-paid entries are in final-liquidation status and are not eligible for Phase 1. Don't panic.
Judge Eaton's April 1, 2026 order in Atmus Filtration, Inc. v. United States (Court No. 26-01259) extended refund eligibility to final-liquidation entries. You do not have to file a protest within the 180-day post-liquidation window to preserve refund rights. Wait for later CAPE phases. CBP has confirmed those phases are coming.
Importers in this bucket should still do the prep work now: identify the entries, calculate the IEEPA portion, document everything. When Phase 2 opens, you want to be ready to file day one — not searching for entry summaries.
What CAN Go Wrong After Filing
A passed validation is not a deposited refund. Three things can still go sideways:
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Compliance review can extend the timeline. The 60-90 day window assumes no compliance issues. A documentation request or audit flag can push that out by months.
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Government appeal of Judge Eaton's underlying refund order. The deadline to appeal to the Federal Circuit is approximately June 7, 2026. If the government appeals and wins, CAPE refund obligations could be paused or reversed. Probability is low but not zero.
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You spend the money before it lands. Don't. Refunds are not deposited until they are deposited. Treat the claim as an accounts-receivable line item with a 60-90 day expected close — not as cash.
For Customs Brokers — How to Prep Clients
If you're a customs broker, your operations queue for the next 30-60 days is set by these five steps.
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Pull every client's IEEPA entries. Run a single query across your ABI system filtered on IEEPA tariff codes, entry dates Feb 2025 - Feb 2026. Generate one report per client.
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Calculate per-client refund estimates. Sum the IEEPA-portion duties paid per client. This is the number they want to know. Round conservatively.
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Email each client with a personalized number. Not "we're working on it" — an actual dollar figure with the timeline. Brokers who send this email retain clients. Brokers who don't will lose them to the broker who did.
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Prep the ACE submission queue. Prioritize unliquidated entries first, then within-80-days. Sort by remaining days-to-liquidation to avoid letting Phase 1-eligible entries roll into final liquidation while you batch.
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Set client expectations correctly. 60-90 days from filing acceptance, not from CAPE launch. Subject to compliance review. Subject to Federal Circuit appeal risk through ~June 7. Don't overpromise.
TariffDesk's pipeline flagged the CAPE launch on April 20 within minutes of CBP's CSMS #68315804 publication — clients tracking IEEPA-affected codes received first-mover alerts.
Sources
- CBP IEEPA Duty Refunds Page
- CSMS #68315804 — CAPE Introduction
- CSMS #68340863 — CAPE Update
- CBP CAPE Phase 1 Trade Information Notice (PDF)
- Learning Resources, Inc. v. Trump Supreme Court Opinion
- Perkins Coie CAPE Phase 1 Guidance
- Baker Tilly: IEEPA Refund CAPE Portal — Processing Signals, Timing and Risks
- Norton Rose Fulbright: CBP Issues Tariff Refund Instructions
Need help tracking which entries qualify for CAPE refunds and when? Monitor your HTS codes with TariffDesk →