CAPE and IEEPA Refunds: What We Know Ahead of April 20

Published April 16, 2026

Key Points

• CBP is targeting April 20, 2026 to launch the CAPE tool for processing IEEPA tariff refunds.
• Approximately 82% of IEEPA entries are eligible for electronic refunds, totaling ~$127 billion.
• CAPE is in final testing, with all four components between 85–95% complete.
• AD/CVD entries (~$2.9B in duties) are excluded from automated processing and require manual handling.
• Phase 1 eligibility hinges on liquidation status, reconciliation flags, and the absence of open protests or drawback claims.
• Importers with entries outside Phase 1 should consider protests or CIT action to preserve refund rights.
• If you believe you have entries eligible for IEEPA duty refunds and would like assistance with CAPE declarations or the filing of protests, please contact ustradeservices@ghy.com

A​​​​​​​​s relayed by the National Customs Brokers & Forwarders Association of America, Inc. (NCBFAA), CBP confirmed that the CAPE system is now in its final testing stage, a few days before the planned rollout.

Brandon Lord, Executive Director of the Trade Programs Directorate, in a statement to the U.S. Court of International Trade (CIT) on April 14, said that the Consolidated Administration and Processing of Entries (CAPE) tool within ACE is undergoing “intensive testing” to support IEEPA tariff refunds.

CBP continues to target April 20, 2026 at 8:00 a.m. ET for deployment and has not announced any delay.

CAPE Development Status

CBP has completed primary development across all CAPE components and transitioned to performance and scenario-based testing. As of April 14, 2026, the four CAPE components are at the following stages.

• Claim Portal: 95% complete
• Mass Processing: 85% complete
• Review and Liquidation/Reliquidation: 90% complete
• Refund Processing: 90% complete

Electronic Refund Coverage for IEEPA Entries

CBP said, “In total, refunds can be issued electronically for approximately 82% of entries with IEEPA duty payments and/or duty deposits. The principal amount of IEEPA duty payments and/or duty deposits for these entries is approximately $127 billion”.

CAPE Phase 1 Eligibility (as of April 20, 2026)

Under Phase 1 of CAPE, an entry may be eligible for an IEEPA duty refund if it meets all the following criteria:

• The entry includes dutiable IEEPA HTS Chapter 99 codes
• The entry is either unliquidated, or liquidated within the last 80 days
• The entry is not flagged for reconciliation, covered by an open protest, part of a drawback claim, more than 80 days past liquidation, or subject to pending AD/CVD liquidation instructions

CBP is evaluating more complex scenarios (including those excluded above) for potential inclusion in future CAPE phases.

CAPE Refund Process
1. Eligibility Review

GHY will review entries to confirm compliance with CBP Phase 1 criteria, including liquidation status, reconciliation flags, and prior filings. GHY will confirm the refund recipient for each entry and the client’s ability to receive electronic refunds via ACH. CBP issues refunds electronically either care of GHY USA (for entries where GHY is the 4811 Notify Party) or directly to the Importer of Record. If a client cannot receive electronic refunds, GHY may file a Post Summary Correction (PSC) to add GHY as the 4811 Notify Party before the IEEPA refund claim is filed in CAPE. Entries not eligible for Phase 1 will be held and monitored for a future CAPE phase.

2. CAPE Filing

GHY will file the CAPE Declaration in the ACE Portal. If a CAPE declaration is rejected, GHY will troubleshoot the rejection and resubmit a corrected claim as appropriate.

3. CBP Review and Processing

Once a claim is accepted in CAPE, CBP generally removes the dutiable IEEPA charges from the entry summary, recalculates duties, and liquidates or reliquidates the entry with a refund of duty as applicable. Further compliance review may be conducted by CBP. Processing may be impacted by ongoing litigation. The current period to file an appeal remains open until June, which could potentially affect submitted CAPE Declarations.

4. Refund Issuance

GHY will monitor claims through the issuance of refunds. Anticipated timelines: unliquidated entries may be refunded within 60–90 days after CAPE acceptance (unless suspended, extended, or under CBP review, in which case refunds are issued at the time of liquidation). Liquidated entries will be re-liquidated one business day following acceptance, triggering refund issuance.

Important Notes on CAPE Filings

• CAPE filings cannot be amended once accepted; additional eligible entries require a new submission
• Each entry may only be submitted once through CAPE
• Post Summary Corrections (PSCs) cannot be used to initiate IEEPA refunds
• Refund timing may vary depending on liquidation status, CBP review, and the status of ongoing litigation

Options for Liquidated Entries Outside CAPE Phase 1

In light of continued uncertainty about refund availability for entries more than 80 days past their liquidation date, and ongoing litigation, two options are available to preserve potential refund rights:

Option 1: CIT Action (Recommended)

Initiating action at the U.S. Court of International Trade (CIT) for liquidated entries outside the 180-day protest period is considered the strongest course of action to preserve potential refund rights. This involves retaining legal counsel to file a Summons and Complaint under 28 U.S.C. § 1581(i) with the CIT, which would encompass both liquidated and unliquidated entries.

Option 2: File Protests Within the 180-Day Statutory Period

Protests must be filed within 180 days of the liquidation date. The recommendation is to file protests for entries between 80 and 180 days from the date of liquidation, continuing on a monthly cadence pending further clarity on when CAPE declarations may be submitted for these entries. GHY can support through GHY Facilitation (reviewing and determining which entries to protest, filing only where IEEPA duty exceeds a minimum threshold set by the client) or Client-Directed List (client provides a monthly list of entries to be protested).

Important Notes on CAPE Filings

• CAPE filings cannot be amended once accepted; additional eligible entries require a new submission
• Each entry may only be submitted once through CAPE
• Post Summary Corrections (PSCs) cannot be used to initiate IEEPA refunds
• Refund timing may vary depending on liquidation status, CBP review, and the status of ongoing litigation

Next Steps You Can Take

If you believe you have entries eligible for IEEPA duty refunds and would like assistance with CAPE declarations or the filing of protests, please contact ustradeservices@ghy.com for an estimated timeline and applicable service fees.

This content is intended for general informational purposes and reflects CBP guidance currently available for CAPE Phase 1. Program scope and eligibility are subject to change based on CBP updates.

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