CAPE Opens April 20: The Official CBP FAQ, Translated Into Plain English

CBP has published its official FAQ for the CAPE refund process, and it answers a number of questions that importers and brokers have been sitting with since the system was announced. Some of the answers are reassuring. A few carry details that will catch people off guard if they do not read carefully. This post goes through all of it.

Starting with the timeline, because it matters for cash flow planning, CBP is now quoting 60 to 90 days for valid IEEPA refunds to be issued following acceptance of a CAPE Declaration. Earlier status updates to the Court of International Trade referenced a 45-day processing window. The official FAQ sets a wider range. If you are modelling when funds will land, plan around the 90-day end of that range and treat anything faster as good news.

Who files, and what they need

Only two parties can file a CAPE Declaration: the importer of record or the licensed customs broker who filed the entries. No other party is authorized. Importantly, a broker can include entries from multiple importers on a single declaration. The cap is 9,999 entries per declaration, and those entries can span different importers of record. For brokers managing large client portfolios, that is a practical efficiency worth knowing before you start organizing your data.

Both the importer and the broker need an ACE Portal account to participate. The importer needs the Importer sub-account within the portal, specifically, because that is where ACH banking information is managed. Without that sub-account structure in place, the banking information cannot be entered, and without banking information, no refund will be issued. CBP is unambiguous on this point: it will hold the refund until the ACH information is available. No exceptions are described.

The 80-day window for liquidated entries

Phase 1 accepts liquidated entries, but with a specific cutoff. The declaration can include entries liquidated within the preceding 80 days from the date of filing. CBP set the window at 80 days, rather than the full 90, to leave enough time to reliquidate before the 90-day voluntary reliquidation deadline under 19 U.S.C. 1501 expires. Once that deadline passes, the entry moves into finally liquidated status and falls outside Phase 1 scope.

This is worth mapping against your entry records before you file. An entry that liquidated 85 days ago is not eligible for Phase 1. An entry that liquidated 75 days ago is. The cutoff is mechanical, not discretionary, so knowing where your entries stand before you build your CSV file will save you from rejected line items.

Declarations cannot be amended

This is the detail that will cause the most headaches for importers who move too quickly. Once a CAPE Declaration is filed and accepted, it cannot be changed. If you discover additional eligible entries after submitting, you file a new declaration covering only the entries not previously submitted. Each entry can appear on exactly one accepted declaration. If you try to include an entry that was already accepted on a prior filing, it will be rejected with an error.

The practical advice here is simple: take the time to compile as complete a list of eligible entries as possible before submitting anything. Run your ACE entry summary data, identify every entry carrying IEEPA HTS codes for the period February 4, 2025 through February 24, 2026, check the liquidation status of each, and verify which ones fall within the 80-day window. Filing a second or third declaration is not a disaster, but it is avoidable with preparation.

How the refund is issued and who receives it

All IEEPA refunds go out electronically via ACH. There are no exceptions for paper checks. The refund goes to the importer of record, or to a party the importer has designated through either CBP Form 4811 or the Notify Parties tab in the ACE Portal. If a Form 4811 designation is in place, the designated party must also have valid ACH banking information on file. Designating a broker or third party that is not set up on ACH does not solve the problem.

Refunds will be consolidated by liquidation or reliquidation date and by importer of record. That means CBP is not issuing one refund per entry. It will batch them together based on when they liquidate and who the importer is. The practical implication is that entries within the same declaration may not all result in payments at the same time if they liquidate on different dates.

Entries with suspended, extended, or under review status

These entries can be included in a CAPE Declaration and will go through the validation process. CBP will remove the IEEPA HTS codes and recalculate the duty. But the refund itself will not come immediately. These entries keep their current liquidation status until that status is resolved in the normal course, at which point the validated refund is issued at liquidation. If you have entries in one of these categories, include them on your declaration, but do not expect the refund on the same timeline as your unliquidated or within-window entries.

What stays out of Phase 1

Six categories of entries are excluded from Phase 1 and will be addressed in subsequent phases. Entries flagged for reconciliation, including Entry Type 09 Reconciliation Summary entries. Entries designated on a drawback claim. Entries covered by an open protest. Entries not filed in ACE or without a liquidation status in ACE. Entries subject to antidumping or countervailing duties for which Commerce has issued liquidation instructions pending liquidation under 19 U.S.C. 1504(d). And entries for which liquidation is already final.

That last category, finally liquidated entries, is the one with the most legal complexity. The Court of International Trade has ordered that these entries must ultimately be covered, and CBP has committed to developing that capability in a later phase. But there is no announced timeline, and for importers with significant exposure in finally liquidated entries, the parallel strategy of filing protests and considering CIT action remains relevant.

Questions and contact

CBP has set up a dedicated inbox for IEEPA refund questions: IEEPARefunds@cbp.dhs.gov. For errors encountered when filing entry summaries, the ACE Help Desk, CBP client representatives, and customs brokers are all listed as appropriate contacts. Given the volume of entries involved and the complexity of the process, having a broker who is actively tracking the CAPE rollout is genuinely useful right now.

How ShipTech can help

Our customs brokerage team has been tracking every CBP update and court order through this process since February. We can help you pull and organize your entry data, confirm your ACE and ACH setup is correct, identify which entries fall within the Phase 1 window versus later phases, and file CAPE Declarations on your behalf. If you want to get ahead of the April 20 launch rather than react to it, reach out to your ShipTech account manager now.