CAPE Phase 1 Is Live: 75,306 Refund Claims Filed in the First Six Days
CBP launched the Consolidated Administration and Processing of Entries (CAPE) system in ACE at 7:11 a.m. ET on April 20, 2026 — and importers and customs brokers responded immediately. Within the first six days, 75,306 CAPE declarations were submitted, covering 11.2 million individual import entries subject to IEEPA duties. Here's what the launch data reveals about the largest customs refund operation in U.S. history.
Day One: A Record Login Spike
CAPE went live at 7:11 a.m. ET on April 20, 2026, six minutes ahead of CBP's published rollout target. By mid-morning, ACE saw a roughly 70% spike in daily logins — the highest single-day login volume CBP has ever recorded against the production ACE platform. Brokers had been queuing entries against the new declaration type for weeks; the moment the gate opened, they pushed.
Filing activity stayed elevated through the first business week. By 8:00 p.m. ET on April 26, CBP's CAPE filing dashboard showed:
| Metric | First 6 Days |
|---|---|
| CAPE declarations submitted | 75,306 |
| Declarations passing initial validation | 47,315 |
| Initial pass rate | 63% |
| Individual import entries accepted for IEEPA-duty removal | 11,222,927 |
Set against the broader refund landscape, the early numbers are remarkable. The Supreme Court's February 20, 2026 ruling in Learning Resources, Inc. v. Trump invalidated approximately $166 billion in IEEPA tariffs collected from an estimated 333,000+ eligible importers across roughly 53 million entries. Phase 1 covers about 63% of those entries — the unliquidated population plus entries within the 80-day reliquidation window — and in six days, brokers have already pushed nearly 21% of that addressable Phase 1 entry pool into the queue.
What the Numbers Tell Us
Three signals stand out in the launch data.
Velocity was broker-driven, not importer-driven. A 75,000-declaration count over six days, with an average of 149 entries per declaration, points to high-volume customs brokers batching entries on behalf of multiple clients. Individual importers filing direct-to-CBP would have produced a much flatter curve. Practitioners writing in the first week confirm what the numbers suggest: the early movers were tech-forward broker operations that had pre-built ABI templates against draft CAPE specs.
A 63% pass rate is high for a Day-1 launch. CBP's own internal projections — referenced in CSMS #68340863 — anticipated initial validation rates closer to 50%. The 13-point upside reflects how thoroughly the trade community had digested CBP's pre-launch guidance, particularly the eligibility checklist published in the April 16 Trade Information Notice.
The 37% rejection rate is still 27,991 declarations that need to be refiled. That backlog will compress filing capacity in week two as brokers triage their failed submissions. Most rejections cluster around a small set of fixable data-quality issues — see Why 28,000 CAPE Filings Got Rejected in the First Week for the breakdown and remediation playbook.
Who Filed First
Filing pattern analysis from Baker Tilly's CAPE portal monitoring suggests three filer cohorts dominated week one:
- Top-50 customs brokers by entry volume — large national brokers with mature ABI integrations and dedicated CAPE task forces. Several reported filing 1,000+ declarations on Day 1 alone.
- Industry verticals with concentrated IEEPA exposure — automotive parts, consumer electronics, and apparel importers, where IEEPA duties represented 15-25% of landed cost during the 2025 collection window.
- Importers of record with in-house trade teams — Fortune 500 importers who file direct-to-CBP rather than through third-party brokers, including several that filed mass declarations on the morning of April 20.
Smaller importers and brokers without ABI hygiene workflows are largely still on the sidelines. Based on the 333,000+ eligible importer count, fewer than one in four eligible IORs is represented in the first-week filing data.
Refund Timeline
CBP guidance puts valid refunds at 60 to 90 days from declaration acceptance, absent compliance review. For declarations accepted on April 20-21, that means refund disbursements landing between mid-June and late July 2026. CBP has not yet confirmed whether disbursements will be batched weekly or processed continuously, but the agency's CSMS update language ("rolling disbursement upon validation closure") points to continuous processing.
What Comes Next
Phase 1 covers approximately 63% of IEEPA-paid entries — the unliquidated population and those within the 80-day reliquidation window under 19 U.S.C. 1501. The remaining ~37% are entries already in final liquidation status, which Judge Eaton's April 1 order in Atmus Filtration, Inc. v. United States extended refund eligibility to without requiring importers to have filed protests within the 180-day window.
CBP's published roadmap targets Phase 2 — covering final-liquidation entries — for Q3 2026, with the exact launch contingent on completion of the four refund-process components currently at 60-85% build status. Brokers should expect a second filing surge when Phase 2 opens; the population of importers with final-liquidated entries is older, larger by entry count, and includes many who have not yet engaged with the refund process at all.
For now, the headline is simple: the largest customs refund operation in U.S. history is live, and the meter is running.
Sources
CBP IEEPA Duty Refunds Page | Baker Tilly: IEEPA Refund CAPE Portal Analysis | Thompson Hine SmarTrade: CBP Confirms April 20 Launch | Perkins Coie: Launch of CAPE Phase 1
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