IEEPA Tariff Refunds: The CAPE Portal Step-by-Step Guide for Importers

After the Supreme Court struck down IEEPA tariffs on February 20, 2026, the question shifted from if importers would get refunds to how. The answer is CAPE — Customs and Border Protection's new Consolidated Administration and Processing of Entries system — a purpose-built module inside the ACE portal designed to handle the largest tariff refund operation in U.S. history.

The numbers are enormous: $166 billion in duties, 53 million entries, 330,000 importers. CBP told the Court of International Trade it cannot process refunds at that scale with existing systems, so it's building CAPE from scratch with a target launch of mid-April 2026.

This guide walks you through every step of preparing for and using the CAPE portal to claim your IEEPA tariff refunds.

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What Is the CAPE Portal?

CAPE (Consolidated Administration and Processing of Entries) is a new capability being added to CBP's existing Automated Commercial Environment (ACE) portal. Rather than processing 53 million individual refund transactions, CAPE will:

• Consolidate all eligible entries per importer into a single refund calculation
• Automate reliquidation of unliquidated entries without requiring individual protests
• Batch process ACH refund payments directly to importers' bank accounts
• Accept CSV uploads for importers who need to submit supporting documentation

CAPE is not a separate website. It will appear as a new module within your existing ACE Portal dashboard once it goes live.

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Which Entries Qualify for CAPE Refunds?

Only duties collected under the International Emergency Economic Powers Act (IEEPA) are eligible. Here is a clear breakdown:

Tariff Program	Legal Authority	Period Collected	Refund Eligible?
"Liberation Day" reciprocal tariffs (10-50%)	IEEPA	April 5, 2025 – Feb 24, 2026	Yes
Fentanyl tariffs on China (20%)	IEEPA	Feb 4, 2025 – Feb 24, 2026	Yes
Fentanyl tariffs on Canada/Mexico (25%)	IEEPA	March 4, 2025 – Feb 24, 2026	Yes
Section 122 global surcharge (15%)	Trade Act §122	Feb 25, 2026 – present	No
Section 232 steel/aluminum (25%)	Trade Expansion Act	2018 – present	No
Section 301 China tariffs (7.5-25%)	Trade Act §301	2018 – present	No
Antidumping/countervailing duties	Various	Ongoing	No

Key point: If you paid tariffs between approximately April 2025 and February 24, 2026 that were labeled as IEEPA actions, those payments are eligible for refund.

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The CAPE Refund Timeline

Here is the realistic timeline based on CBP's filings with the Court of International Trade:

Milestone	Expected Date	Status
CIT orders reliquidation	March 5, 2026	Completed, then suspended
CBP requests 45-day extension	March 6, 2026	Granted
CAPE portal development	March–April 2026	In progress
CAPE portal launch	Mid-April 2026	Target
First automated refunds (unliquidated entries)	May–June 2026	Pending
Protest-based refunds (liquidated entries)	Q3–Q4 2026	Pending
Complex/contested cases	2027–2031	Pending

The CIT initially ordered CBP to begin reliquidation on March 5, but suspended the order the next day after CBP demonstrated it physically could not comply at scale. The 45-day development window gives CBP until approximately April 20 to launch CAPE.

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Step-by-Step: How to Prepare for CAPE

Step 1: Identify Your IEEPA Entries

Work with your customs broker or review your ACE portal records to create a comprehensive list of all import entries where you paid IEEPA-based duties. You need:

• Entry numbers for every affected shipment
• Entry summary dates (CBP Form 7501 filing dates)
• IEEPA duty amounts paid per entry
• Country of origin for each shipment
• HTS classification codes used

Focus on the window between your first IEEPA-affected entry (as early as February 2025 for fentanyl tariffs, April 2025 for Liberation Day tariffs) and February 24, 2026.

Tip: Use our HS Code Lookup tool to verify which of your product classifications were subject to IEEPA tariffs.

Step 2: Gather Entry Summaries and Documentation

For each affected entry, compile:

• CBP Form 7501 (Entry Summary) — the primary document showing duties paid
• Commercial invoices from your suppliers
• Bills of lading or airway bills
• Packing lists with detailed product descriptions
• Country of origin certificates or manufacturer declarations
• Proof of payment (bank records showing duty payments to CBP)

Organize these by entry number. CAPE is expected to accept CSV uploads for batch documentation, so having your records in spreadsheet format will speed up the process.

Step 3: Check the Liquidation Status of Each Entry

The liquidation status of your entries determines your refund pathway. Log into ACE and check each entry:

Status	What It Means	Your Action
Unliquidated	CBP has not finalized the duty amount	No action needed — CAPE will auto-reliquidate
Liquidated < 180 days ago	Finalized recently	File a protest (Form 19) to preserve rights
Liquidated > 180 days ago	Finalized more than 6 months ago	Consult a trade attorney — options are limited

For unliquidated entries, CAPE should process your refund automatically. For recently liquidated entries, filing a timely protest is critical to preserving your refund rights.

Step 4: Register for ACE Portal Access

If you don't already have an ACE Portal account, apply now at ace.cbp.dhs.gov. Registration requires:

1. An active Employer Identification Number (EIN)
2. A Customs Bond on file with CBP
3. Designation of an Account Owner with authority to manage refunds
4. Completion of the ACE Secure Data Portal application

Processing time for new accounts can take 2-4 weeks, so do not wait until CAPE launches.

Step 5: Set Up ACH Direct Deposit

CAPE refunds will be issued exclusively via ACH electronic transfer. No paper checks will be mailed. To set up or verify ACH:

1. Log into ACE Portal
2. Navigate to Account Management > Payment Profiles
3. Add or verify your bank routing number and account number
4. Confirm the account is a business checking account (personal accounts may be rejected)
5. Complete any required micro-deposit verification

If your banking information has changed since you filed your entries, update it in ACE immediately.

Step 6: Prepare Your CSV Upload File

CBP has indicated CAPE will support batch claims via CSV upload. While the exact format hasn't been published yet, prepare a spreadsheet with these columns based on CBP's preliminary guidance:

Column	Description	Example
Entry Number	15-digit CBP entry number	123-4567890-1
Entry Date	Date of entry summary	2025-07-15
HTS Code	10-digit classification	8471.30.0100
Country of Origin	ISO country code	CN
Declared Value	Customs value in USD	50000.00
IEEPA Duty Paid	Amount of IEEPA duty	7500.00
Liquidation Status	Current status	Unliquidated

Start building this file now. When CAPE launches and publishes the official CSV template, you'll be able to quickly reformat your data.

Step 7: File Protests for Liquidated Entries

For any entries that have already been liquidated (finalized) within the past 180 days, file a protest using CBP Form 19 through the ACE Portal:

1. In ACE, navigate to Protests > File New Protest
2. Select the relevant entry number
3. Choose 19 U.S.C. § 1514 as the protest basis
4. Reference the CIT's March 5 order in Atmus Filtration, Inc. v. United States
5. Specify the IEEPA duty amount you're contesting
6. Submit electronically — keep the confirmation number

The 180-day clock runs from the date of liquidation, not the date of entry. Check your liquidation notices carefully.

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How Much Could You Receive?

Your refund amount equals the total IEEPA duties you paid during the eligible period. Here are examples across business sizes:

Business Type	Monthly Imports	IEEPA Rate	Months Paying	Est. Refund
Small retailer	$50,000	20% (China fentanyl)	12	$120,000
Mid-size manufacturer	$500,000	34% (China reciprocal)	10	$1,700,000
Large distributor	$2,000,000	46% (Vietnam)	8	$7,360,000
Multi-source importer	$1,000,000 (avg)	25% (blended)	10	$2,500,000

These are estimates. Actual refunds depend on precise entry-level data and which tariff programs applied to your specific products.

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Common Pitfalls to Avoid

1. Assuming all tariffs are refundable. Only IEEPA duties qualify. Section 122, Section 232, and Section 301 tariffs are still in effect and non-refundable.

2. Missing the 180-day protest deadline. For liquidated entries, this window is firm. Once it passes, your options are severely limited.

3. Incorrect importer of record. Refunds go to the importer of record on file with CBP, not necessarily the entity that economically bore the tariff cost. If you purchased from a domestic distributor, the refund goes to the distributor.

4. Outdated banking information. ACH failures will delay your refund. Verify your ACE payment profile now.

5. Not consolidating documentation early. Importers with clean, organized records will receive refunds faster than those who scramble after CAPE launches.

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What Happens After CAPE Launches?

Once CAPE goes live (expected mid-April 2026), the process should be:

1. Log into ACE — CAPE will appear as a new module
2. Review your consolidated statement — CAPE will show all identified IEEPA entries
3. Verify the amounts — Check that all eligible entries are included
4. Upload supplemental CSV if any entries are missing
5. Confirm ACH details — Verify your bank account
6. Submit your claim — Electronically confirm you want to proceed
7. Receive ACH payment — Timeline varies, but unliquidated entries should process first

CBP may stagger refunds by importer size or entry count. Monitor the CBP Trade website and your ACE notifications for updates.

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How TariffCenter.AI Can Help

Our platform offers several tools to help you prepare for CAPE:

• Refund Status Tracker — Monitor CBP's refund processing timeline
• CF-7501 AI Parser — Upload entry summaries for automated analysis
• HS Code Lookup — Verify tariff classifications for your products
• AI Chat Assistant — Ask questions about your specific refund situation

Start preparing now. The importers who have their documentation ready when CAPE launches will be first in line for refunds.