Trade Compliance Professionals – Your “CAPE” Crusader!

CBP is developing the CAPE (Consolidated Administration and Processing of Entries) system within ACE to process refunds of duties imposed under IEEPA. As of March 30, 2026, CBP estimates that development of the four CAPE components is as follows: Claim Portal is about 85% complete, Mass Processing about 60% complete, Review and Liquidation/Reliquidation about 80% complete, and Refund about 75% complete. CBP further estimates that Phase 1, as currently designed, will be able to process roughly 63% of entries on which IEEPA duties were paid or deposited.  The system will initially exclude finally liquidated entries per CBP’s plan to keep Phase 1 on schedule, with that functionality targeted for a later phase.

Importers seeking to recover IEEPA duty should monitor CBP announcements regarding Phase 1 operational launch. While CBP projects a 45-day review, reliquidation, and refund process, the system is not yet functional, and importers should begin preparing now for future CAPE Declaration submissions once the system is operational.

For importers, this recent update from CBP means Phase 1 will provide significant albeit incomplete relief and in light of the declaration and the CIT’s orders, it would be wise for importers to:

• review entries on which IEEPA duties were paid or deposited and identify which are Phase 1‑eligible (unliquidated or within the 90‑day window) versus those that will depend on later phases.
• Audit entries eligible for IEEPA duty refund to ensure CBP validation readiness; immediately submit entries with errors for correction prior to submission into CAPE.
• Quantify exposure for finally liquidated and other excluded entries, now within the potential scope of court‑ordered relief.
• Ensure electronic refund readiness, including enrollment in ACE, ACH account set-up, and CBP Form 4811 designations
• Continue to monitor further CBP and court guidance on the rollout and scope of subsequent CAPE phases.

Contact TCP today and find out how we can put your organization on the path toward being fully prepared to apply for your IEEPA duty refunds.

Trade Compliance Professionals. Your “CAPE Crusader” in the fight to recover IEEPA tariffs!