The U.S. Supreme Court’s recent decision to strike down certain tariffs imposed under the International Emergency Economic Powers Act (IEEPA) has created an opportunity for many small businesses to seek refunds. However, navigating the refund process can be complex. For a detailed guide on how to access tariff refunds, visit the U.S. Chamber’s Guide on Tariff Refunds, here.
Here is a short summary of what is featured in the full guide:
On April 20, U.S. Customs and Border Patrol launched phase one of the tariff refund process. The new portal will refund duties to importers through CBP’s Automated Commercial Environment (ACE) system, which is well known to importers. CBP is calling this new ACE functionality the Consolidated Administration and Processing of Entries (CAPE) system.
More details about the refund process on the IEEPA Duty Refunds website. The site contains instructions on how importers will be able to file for refunds through an electronic system
[To learn more about the Supreme Court decision and what tariffs are impacted, watch our Small Business Tariff Update.]
CAPE: IEEPA Duty Refund Processing — What to Know
U.S. Customs and Border Protection (CBP) is building a new system — Consolidated Administration and Processing of Entries (CAPE) — to handle IEEPA duty refunds more efficiently.
Instead of processing refunds one entry at a time, CAPE will consolidate them, including interest, into a streamlined process within CBP's existing ACE (Automated Commercial Environment) platform. It's being rolled out in phases, with Phase 1 launching April 20, 2026, initially covering only certain unliquidated entries and entries within 80 days of liquidation. More complex scenarios will be handled in later phases. For a more detailed explanation and a full list of FAQs, click here to read more on CBP.gov.
The information below is adapted directly from CBP's official CAPE FAQs. Here are some key highlights to know:
- Filing a declaration:
- Only the IOR or the licensed customs broker who filed the entries can file a CAPE Declaration.
- IORs and brokers must have an ACE Portal account and ensure that their bank account information for refunds has been added to their account. For more information see: Applying for an ACE Portal Importer Account and Enrolling in ACH Refunds.
- You can file all eligible entry summaries on one CAPE declaration, whether or not they have liquidated and whether or not they share the same upcoming liquidation date.
- Recordkeeping requirements: There are no new recordkeeping requirements for the CAPE Declaration. You should continue to follow all applicable recordkeeping requirements.
- Declaration status: CBP will not email CAPE updates. You should use ACE Reports to keep track of your refund or request this information from your customs broker if your broker filed your CAPE Declaration on your behalf.
- If accepted: When you file a CAPE Declaration by uploading your .CSV file in the ACE Portal, the file itself, as well as the entry summaries listed, will be validated and you will receive a CAPE claim number. This indicates that the CAPE Declaration is accepted and will continue processing for the accepted entries.
- If rejected: Any entry summaries that are not accepted will be removed from the Declaration, with all valid entry summaries remaining to continue through the process. The filer can view which entry summaries were accepted or rejected, and the reason for rejection.
- Entry correction or amendment: Once a CAPE Declaration has been filed and accepted, it cannot be amended. However, if you found additional entries eligible for refund after submitting a CAPE Declaration, you can file a new CAPE Declaration with those entries not previously submitted. Entries on a CAPE Declaration will receive a rejection error if they were included on a previous Declaration.
- Liquidated & pending entries: During Phase 1, ACE will accept CAPE Declarations containing entries liquidated within the preceding 80 days. Additionally, entries with a liquidation status of suspended, extended, or under review may also be included — these will maintain their liquidation status until resolved, with validated refunds issued at liquidation.
- Issuance of refunds:
- Importers and authorized brokers should anticipate that valid IEEPA refunds will generally be issued within 60 - 90 days following acceptance of the CAPE Declaration, unless a compliance concern requires further CBP review.
- All refunds are required to be paid electronically via Automated Clearing House (ACH). CBP is only able to refund IEEPA duties to the Importer of Record or the Notify Party (designated on CBP Form 4811) who have their U.S. bank account information in their ACE Portal account. See more information at ACH Refund Enrollment Overview. If you have not updated your ACE Portal account with your current ACH information, you will not receive a refund.
- Interest will be included in your IEEPA duty refund. The calculation of interest generally starts from the date of deposit or estimated duty payment to the date of liquidation or reliquidation of the applicable entry.
- Fees: CBP does not charge any fees for processing tariff refunds. If you are asked to pay a fee or provide financial information by a party claiming to be CBP, it is a scam and you should report it to the Traderelations@cbp.dhs.gov mailbox.
- Outstanding bills: A CAPE Declaration may be filed whether or not the filer has outstanding bills from CBP that include IEEPA duties owed. CBP has paused collection and enforcement actions at this time for any bill(s) that include unpaid IEEPA duties. However, if the bill(s) also include(s) unpaid amounts other than IEEPA duties (and interest on IEEPA duties), these non-IEEPA related amounts remain due.
- Scams/security: With the launch of CAPE, CBP expects that scammers will attempt to use social media, email, and other communication methods to secure account information from importers in order to interfere with the process of refunding IEEPA. Learn more about what to watch out for and protect your information.
- Questions: For more questions on how to create an ACE account and who to contact about refunds, see the guidance CBP has developed for ACE accounts and ACH Refunds here.
- For technical questions about IEEPA refunds, email: IEEPARefunds@cbp.dhs.gov
- For general inquiries about IEEPA refunds, email: traderelations@cbp.dhs.gov
The U.S. Chamber of Commerce is closely monitoring developments and advocating for a simple, efficient refund process. Stay informed and take proactive steps to prepare for refunds. For more resources, visit the Chamber’s Guide on Tariff Refunds, here.
CO—is committed to helping you start, run and grow your small business. Learn more about the benefits of small business membership in the U.S. Chamber of Commerce, here.
