CAPE Is Coming: What Importers Need to Know About CBP's IEEPA Refund System

On March 12, 2026, Customs and Border Protection provided the Court of International Trade with its first detailed progress report on the system it is building to process IEEPA tariff refunds. The system, called CAPE (short for Consolidated Administration and Processing of Entries), represents CBP's answer to one of the most operationally complex challenges in the agency's history: returning approximately $166 billion in invalidated tariffs to roughly 330,000 importers across an estimated 53 million import entries.

The Legal Context: How We Got Here

The path to CAPE began on February 20, 2026, when the U.S. Supreme Court ruled 6 to 3 that the International Emergency Economic Powers Act does not authorize the president to impose tariffs. This power rests with Congress alone. That ruling invalidated all IEEPA tariffs collected since February 4, 2025, and immediately raised the question of how CBP would return the funds. The collection of IEEPA tariffs ended at midnight on February 24, 2026.

On March 4, Court of International Trade Judge Richard K. Eaton directed CBP to begin refunding IEEPA tariffs to all importers of record, regardless of whether they had filed suit. CBP responded two days later by advising the court that entry-by-entry refund processing was not operationally feasible at the scale required, and proposed building a new, purpose-built system to handle it. The CIT agreed to pause immediate refund execution and gave CBP time to develop and implement that system, with a progress report due March 12. That report is what introduced CAPE to the trade community.

What CAPE Is and How It Will Work

CAPE will live within ACE as a dedicated module, with a new tab visible in both the importer and the customs broker portal accounts. Importers and brokers will initiate the process by submitting a CAPE Declaration through the Claim Portal and uploading a CSV file listing all entry summaries for which they are requesting IEEPA duty refunds. ACE will then run automated validations against the submitted entries, checking both the file itself and the underlying entry data for accuracy.

Once validated, the Mass Processing component will strip the IEEPA-specific HTS numbers from each entry and recalculate the duties owed as if those tariffs had never been applied. This is the core of the refund calculation. Following that, the Review and Liquidation component will set a liquidation or reliquidation date for the affected entries, giving CBP a window to conduct any required manual review before the entries are finalized. Liquidations will be processed Monday through Thursday each week. Once an entry reaches its scheduled liquidation date, the Refund component takes over, directing the overpaid amounts through the ACE Collections module and issuing payment electronically to the bank account on file. Importantly, importers can designate a third party to receive refunds on their behalf by completing CBP Form 4811. This provision may be significant for companies that have sold or assigned their refund claims.

Where Development Stands Today

CBP has structured CAPE as a phased rollout, with basic functionality coming first and more complex scenarios addressed in later releases. As of March 11, the four components are at different stages of completion. The Review and Liquidation component is the furthest along, at 80%. The Claim Portal is 70% complete, with the user interface finished and automated validation logic currently in development. The Refund component is 60% complete, with performance testing of the refund consolidation process currently underway. The Mass Processing component is the least advanced at 40% complete, with development currently focused on the automated entry summary update process.

CBP originally indicated the system could be operational within 45 days of March 6, placing the initial target around mid-April 2026. The first phase will be able to process the majority of formal and informal entries on which IEEPA duties were paid. Entries that are subject to antidumping or countervailing duties, or those with a liquidation status of Suspended, Extended, or Under Review, along with certain other entry types such as warehouse withdrawals and entries on drawback claims, will not be eligible in the initial phase and will be addressed in subsequent development.

What Importers Should Be Doing Right Now

CBP has been clear that importers should not attempt to file any claims until official guidance is issued and the system goes live. Post-summary corrections and protests related to IEEPA tariffs are currently being automatically rejected. However, the preparation work that happens before the filing window opens is exactly what will determine how smoothly the process goes.

The most urgent action for any importer is to enroll in ACH. As of February 6, 2026, CBP no longer issues paper refund checks. All refunds are now issued electronically through ACE via the Automated Clearing House program. If a refund is issued to an importer not properly enrolled in ACH, it will be placed in reject status and delayed until the account information is updated. If your organization has not yet enrolled, it must happen before anything else.

Along with ACH enrollment, importers should now be pulling their entry data. Using ACE reports, specifically the Entry Summary Details report, importers should identify every entry that carries IEEPA-specific Chapter 99 HTS classification codes for the period from February 4, 2025, through February 24, 2026. CBP has noted that many importers combine IEEPA duties and standard duties on the same entry summary line rather than separating them by HTS code, which may require careful manual review to isolate the exact IEEPA amounts. Importers should also check the liquidation status of each entry, as liquidated, unliquidated, and suspended entries follow different paths through CAPE.

There is also a broader strategic question worth raising with legal counsel and financial advisors. Some importers are currently being offered buyout arrangements in exchange for assigning their refund rights, with offers in some cases exceeding 60% of the anticipated refund value. Whether that trade-off makes sense depends entirely on each company's cash position, risk tolerance, and the size of the recovery at stake. It is not a decision to make quickly or without proper advice.

How ShipTech Can Help

ShipTech's customs brokerage team has been tracking the IEEPA refund process since the Supreme Court ruling, and CAPE is a direct extension of the compliance work we do every day. We can help you run entry-level analysis to identify and quantify your IEEPA exposure, set up your ACH refunds through ACE, organize and prepare the entry data for CAPE Declaration submissions, and stay ahead of each phase of CBP's guidance as it is released. If you imported goods subject to IEEPA tariffs in 2025, there is a meaningful recovery opportunity, and the preparation you do before the portal opens will determine how efficiently you capture it.

What to Watch For

CBP has committed to providing detailed guidance on each phase of CAPE as it is deployed. The government also has until approximately early May 2026 to appeal the CIT's March 4 order, a development worth monitoring for any importers weighing their options. ShipTech will continue publishing updates as CBP releases further guidance on CAPE's launch timeline and functionality.

If you are a current ShipTech customer with questions about your specific entries, ACH setup, or preparing for the CAPE filing process, reach out to your dedicated account manager directly.

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