IEEPA Refunds Under CAPE: What Importers Need to Know

U.S. Customs and Border Protection (CBP) has officially launched Phase 1 of the Consolidated Administration and Processing of Entries (CAPE) system within the Automated Commercial Environment (ACE).

This marks a significant shift in how importers and brokers handle post-entry corrections and duty refunds — particularly for entries impacted by prior **IEEPA-related tariffs**.

Here is a breakdown of the recent changes and how to prepare operationally:

Key Takeaways

• CAPE introduces a standardized, electronic process for IEEPA duty refunds
• Phase 1 applies to unliquidated entries and entries liquidated within 80 days
• All submissions are made via the ACE Portal (not ABI) using CSV uploads
• Refunds will be issued exclusively via ACH (no paper checks)
• Expected refund timeline: ~60–90 days after acceptance

What’s Changing

1. Centralized Refund Processing Through CAPE CBP is moving toward a more structured and scalable approach to post-entry corrections. Instead of fragmented processes (PSCs, protests, manual workflows), CAPE creates a dedicated pathway specifically for IEEPA-related refund requests.
2. Fully Electronic Submission and Refunds Phase 1 formalizes a shift already underway:

• Submissions are made via the ACE Portal (CAPE module)
• Entry data is uploaded via CSV file format
• Refunds are issued only via ACH This eliminates paper-based workflows entirely and reinforces the need for proper ACE configuration.

3. Defined Eligibility Window CAPE Phase 1 introduces clear eligibility criteria:

• Eligible: Unliquidated entries and entries liquidated within 80 days
• Not Eligible (Phase 1): Drawback entries, reconciliation entries, ADD/CVD entries, entries under active protest, and entries with final liquidation

How the CAPE Declaration Process Works

At a high level, CAPE follows a four-step workflow:

**1. Submission

• **Filed via ACE Portal (CAPE tab)
• CSV upload with entry-level data
• System validation flags errors prior to acceptance

**2. Processing

• **IEEPA duties are removed
• Entry is updated and refund amount calculated

**3. Review & Liquidation

• **CBP reviews submitted entries
• Entries are liquidated or reliquidated as applicable

**4. Refund

• **Issued via ACH to the Importer of Record (IOR) or authorized party
• Typical timing: ~60–90 days after acceptance

Operational Considerations

• Confirm IEEPA applicability and validate entries before submission Identify which entries were subject to IEEPA duties and confirm they fall within CAPE Phase 1 scope (unliquidated or within 80 days of liquidation), excluding ineligible entry types. Validate entry numbers, duty application, and overall accuracy when consolidating the CSV file, as errors at submission will result in rejected entries and delays.
• Align early with your customs broker and confirm IOR responsibility Only the IOR or filing broker can submit CAPE declarations, making early coordination important to confirm scope, data accuracy, and submission ownership. Many importers will rely on their customs broker to support entry review and help ensure filing accuracy. The Importer of Record remains responsible for providing complete and accurate entry data and retains regulatory responsibility.
• Ensure ACE and ACH setup are in place Confirm the importer has an active ACE Portal account with access to CAPE, along with ACH configured for refunds. Proper setup is required for refunds to be issued.

Ongoing Support from CLM

At CLM, we support our clients and partners through the operational side of CAPE: from identifying eligible IEEPA entries and validating data for submission to ensuring ACE accounts are properly configured for refunds.

As processes continue to evolve, our team remains focused on helping clients navigate post-entry actions with clarity, accuracy, and compliance.

• For more insights, visit our *Medium blog or follow us on [LinkedIn](https://www.linkedin.com/company/compass-logistics-marine)*.
• Need support with CAPE submissions or entry review? **Contact us** to schedule a consultation with our team.

Compass Logistics & Marine (CLM) is a Fort Lauderdale-based, veteran-owned international logistics company specializing in customs brokerage, import and export services, trucking, and warehousing. Supported by a worldwide partner and agent network, and key certifications including IATA and FMC, CLM delivers customized, compliant, and cost-effective logistics solutions across its specialized divisions — CLM Tech, Yacht, Marine & Aviation, General, and Industrial. CLM was recently named Global Affinity Alliance (GAA) Best Partner of the Year in recognition of the team’s excellence in global collaboration and service performance.

For more information, visit compasslogisticsmarine.com.