TL;DR
- CAPE Phase 1 launched April 20, 2026 at 8:00 a.m. EDT in the ACE Secure Data Portal. It is the consolidated path for requesting refunds of IEEPA tariffs collected between February 1, 2025 and February 24, 2026, after the Supreme Court struck them down in Learning Resources, Inc. v. Trump (No. 24-1287, decided February 20, 2026, 6 to 3) and Executive Order 14389 terminated collection.
- Phase 1 covers unliquidated entries and entries within 80 days of liquidation (still inside the 90-day voluntary reliquidation window of 19 USC 1501). About 63 percent of IEEPA-paying entries qualify. Finally liquidated entries, reconciliation entries (Type 09), entries with open or suspended protests, AD/CVD entries with Commerce-suspended liquidation, and drawback claims are all excluded from Phase 1.
- Only the IOR or the licensed broker who filed the entry can file. A CAPE Declaration is a CSV file of up to 9,999 entry numbers, uploaded in the ACE Portal. ACH bank-account information must already be on file with CBP, or refunds are held. Refunds are issued within 60 to 90 days of declaration acceptance, plus statutory interest under 19 USC 1505.
- Re-run any past entry through the Tandom calculator at tariffs.tandom.ai/calculator to see exactly which 9903.01 or 9903.02 codes applied and the dollar amount that is now refundable.
What CAPE is and why it exists
CAPE stands for Consolidated Administration Processing Entries. It is a CBP refund mechanism designed to process IEEPA duty refunds in bulk, after the Supreme Court ruled the International Emergency Economic Powers Act does not authorize tariffs.
The Court's decision in Learning Resources, Inc. v. Trump (No. 24-1287, decided February 20, 2026, 6 to 3) held that 50 USC 1701 et seq. authorizes economic sanctions and asset freezes but not tariffs, voiding the IEEPA-based duties that had been in effect since February 2025. Executive Order 14389 (FR Doc 2026-03832, signed February 20, published February 25, 2026) terminated all collection of IEEPA duties effective 12:01 a.m. ET on February 24, 2026, and directed CBP to refund the duties already paid.
IEEPA tariffs were not eliminated, just relocated. The same EO and the companion Proclamation 11012 (FR Doc 2026-03824) installed a 10 percent Section 122 temporary import surcharge under 19 USC 2132, effective February 24, 2026 and expiring July 24, 2026 absent congressional extension. Section 122 entries are not refundable under CAPE; only the pre-February-24 IEEPA duties are.
CBP collected roughly $130 to $175 billion in IEEPA duties across about 8 million entries between February 1, 2025 and February 24, 2026. The agency designed CAPE to handle that volume without requiring 8 million individual protests under 19 USC 1514 or 19 USC 1520(d). The CAPE process replaces per-entry refund work with a CSV upload and a single declaration covering up to 9,999 entries.
Phase 1 eligibility
Phase 1 covers two categories of entries on which IEEPA duties were paid:
- Unliquidated entries. Any entry where CBP has not yet completed final liquidation under 19 USC 1500. The vast majority of entries filed in late 2025 and early 2026 fall in this category because CBP has 314 days from entry to liquidate (19 USC 1504), and many entries from that window are still pending.
- Entries within the 90-day voluntary reliquidation window. Under 19 USC 1501, CBP can voluntarily reliquidate within 90 days of the original liquidation. Practically this means entries liquidated within the previous 80 days when the CAPE Declaration is filed (CBP needs 10 days to process the acceptance, leaving 80 of the 90).
CBP's notice estimates Phase 1 covers about 63 percent of all IEEPA-paying entries.
What Phase 1 explicitly excludes:
- Finally liquidated entries (more than 90 days past liquidation). These need a 19 USC 1514 protest, filed within 180 days of liquidation, or they wait for Phase 2.
- Reconciliation entries (Type 09). The reconciliation framework adjusts entered value or 9802 claims separately, and CBP has not built CAPE handling for the Type 09 cycle.
- Entries with open or suspended protests under 19 USC 1514. The protest is the live proceeding; resolve it through normal protest channels, not CAPE.
- AD/CVD entries with Commerce-suspended liquidation. The relevant entries cannot be liquidated until Commerce instructs CBP, so CAPE cannot disburse a refund on them. Wait for the order's administrative review or until Commerce lifts the suspension.
- Entries with open drawback claims. The same IEEPA duty cannot be refunded twice (once via drawback under 19 USC 1313 and once via CAPE).
- Entries not filed in ACE. CAPE is built on top of the ACE portal data; non-ACE entries are not addressable.
Run a quick sort against the entry list before opening ACE: drop liquidated-over-90-days entries into a Phase 2 queue, drop AD/CVD-suspended entries into the watch list, flag any open protests, and the rest is the Phase 1 population.
ACE Portal and ACH setup
Two prerequisites must be in place before the CAPE Declaration will accept your CSV.
1. ACE Secure Data Portal account with CAPE access
The CAPE Declaration is a tile inside the ACE Secure Data Portal at ace.cbp.gov. Existing brokers and IORs already have ACE accounts; the CAPE tile appeared automatically on April 20, 2026 for any account with the broker or importer role. New users go through the standard ACE registration first; CAPE adds no extra credentialing step.
2. ACH refund account on file with CBP
CBP issues every CAPE refund by ACH. The bank account must already be on file in ACE (Account Management → Refunds → ACH Refund Account) at the time the CAPE Declaration is submitted. If no account is on file, CBP will accept the declaration but hold the refund disbursement until the account is added, which adds two to four weeks to the timeline.
The ACH account is per IOR for IORs filing on their own behalf, and per broker for brokers filing on behalf of multiple IORs. Brokers handling refunds for multiple importers should confirm with each importer in advance which account the refund should land in. CBP routes the refund to the account associated with the IOR's record, not the broker's, by default.
The CAPE CSV file
The CAPE CSV is the simplest filing format CBP has ever published. The file contains only entry numbers, one per row, with no other columns.
Format rules:
- One entry number per row. No header row required, but a single header line of
entry_numberis accepted. - Maximum 9,999 entry numbers per file. Files exceeding this are rejected at upload. Larger populations must be split across multiple CAPE Declarations.
- Entry numbers are 11 digits in the standard CBP format (3-digit filer code + 7-digit serial + check digit), no dashes. CBP's template enforces this format.
- Entry numbers can span multiple IORs. A broker who filed for 30 different importers can include all of them on one CAPE Declaration, as long as the broker filed each entry.
- UTF-8 encoding, no BOM. Excel exports can introduce a UTF-8 BOM; check the file with
file -i <file.csv>before upload.
The ACE Portal's CAPE tile provides a downloadable template. Use it. Hand-built CSVs that look right but have an extra column, a trailing comma, or a non-CRLF line ending are the most common cause of upload rejections.
Filing the CAPE Declaration
The full flow inside the ACE Portal, in the order CBP presents the screens.
Step 1. Open the CAPE tile
Sign into ace.cbp.gov. The CAPE tile sits on the main dashboard for any account with the broker or importer role. Click "New CAPE Declaration."
Step 2. Confirm filer identity
ACE pre-fills the filer code and asks the user to confirm they filed every entry that will appear in the CSV. There is no way to file CAPE for entries the user did not file. CBP validates this at acceptance.
Step 3. Upload the CSV
Drag and drop or click to browse. The portal validates the format synchronously: entry-number digit count, file size (max 9,999 rows), encoding, and that every entry number exists in ACE under the filer's code. A failed file shows the first 10 errors and the file is not stored.
Step 4. Review the CAPE summary
ACE returns a summary table by IOR: how many entries, how much IEEPA duty was paid in aggregate, how many entries are eligible (unliquidated or within the 80-day window), and how many were rejected (already liquidated more than 90 days, in protest, AD/CVD-suspended, etc.). Rejected entries are flagged with a reason code so the broker can route them to Phase 2 or to a 19 USC 1514 protest.
Step 5. Certify and submit
The certification language tracks the standard ACE entry summary certification: the filer attests under penalty under 18 USC 1001 that the entries listed had IEEPA duties paid in good faith and that no other refund mechanism (drawback, prior protest) is in flight on the same dollars. Submit. ACE returns a CAPE Declaration ID immediately.
Step 6. Track acceptance (about 10 days)
CBP performs a back-end review on the declaration over the next 10 days, confirming that each entry is in the eligible population and that the duty paid under IEEPA codes (9903.01.*, 9903.02.*, 9903.96.01, 9903.96.02) matches the ACE entry summary. The declaration moves from "Submitted" to "Accepted" or, on a partial mismatch, to "Accepted with Exceptions" with a per-entry exception list.
After acceptance: 60 to 90 days
CBP commits to disbursing the refund within 60 to 90 days of declaration acceptance. The clock breaks down roughly:
- Submission to acceptance: 10 days. CBP validates the population and routes any rejected entries back with reason codes.
- Acceptance to liquidation: about 45 days for unliquidated entries. CBP liquidates each unliquidated entry at the IEEPA-stripped rate, which is mechanically equivalent to a 19 USC 1501 voluntary reliquidation for entries already liquidated.
- Liquidation to ACH credit: 5 to 30 days. The Treasury disbursement queue is the bottleneck.
The refund includes statutory interest on the duty amount under 19 USC 1505, calculated from the date the duty was deposited to the date of refund. CBP uses the IRS underpayment rate for the period (currently 8 percent annualized as of Q2 2026, posted quarterly under 26 USC 6621).
MPF and HMF are not refunded by CAPE. Those are user fees, not IEEPA duties, and the authority for them was unaffected by Learning Resources. Section 232, Section 301, and MFN duties on the same entries also remain in place; CAPE touches only the IEEPA Chapter 99 layers.
Worked example
A broker has 4,200 entries spanning February 1, 2025 to February 24, 2026 across 18 IORs. All paid IEEPA duties under some combination of 9903.01.* codes. About 2,650 are unliquidated; 530 are within 80 days of liquidation; the rest are finally liquidated and need to wait for Phase 2 or file 19 USC 1514 protests.
The Phase 1 population is 3,180 entries, well under the 9,999 limit, so a single CAPE Declaration will cover them. One representative line in that population is below: pillows under HTS 9404.90.20.60, China origin, entry September 15, 2025, declared value $50,000.
| 9404.90.20.60Other fill | MFN | 6% | $3,000.00 |
| 9903.88.15Section 301 List 4A | S301 | 7.5% | $3,750.00 |
| 9903.01.25IEEPA reciprocal baseline | IEEPA | 10% | $5,000.00 |
| 9903.01.24IEEPA China fentanyl | IEEPA | 20% | $10,000.00 |
| MPFMerchandise Processing Fee | MPF | 0.3464% | $173.20 |
| HMFHarbor Maintenance Fee | HMF | 0.125% | $62.50 |
| Total duty + fees paid at entry | $21,985.70 | ||
| CAPE-refundable (IEEPA only, plus statutory interest) | $15,000.00 | ||
The broker pulls all 3,180 entry numbers into a single UTF-8 CSV, uploads it to the CAPE tile, certifies, and submits. ACE accepts within 9 days. CBP issues the $5,610,000 aggregate refund (rough estimate from the 3,180 entries' IEEPA layers, plus statutory interest) in two ACH tranches over the following 50 days, splitting between the 18 IORs based on each IOR's recorded ACH account.
Phase 2 and protests for excluded entries
Roughly 37 percent of IEEPA-paying entries fall outside Phase 1. CBP has not committed to a Phase 2 launch date as of May 2026. The protest clock keeps running regardless.
Finally liquidated entries
For entries liquidated more than 90 days ago, the only live refund mechanism is a 19 USC 1514 protest, which must be filed within 180 days of liquidation. After 180 days the liquidation becomes final and binding, and the entry is permanently excluded from any refund (Phase 2 or otherwise) unless Phase 2 carves out a separate path.
The conservative play is to file 1514 protests on every finally-liquidated IEEPA entry as the 180-day deadline approaches, even if Phase 2 is rumored to be imminent. The protest preserves the refund right; CBP can deny in favor of the eventual Phase 2 process if Phase 2 launches first. Letting 180 days lapse without a protest forecloses the right entirely.
AD/CVD-suspended entries
Entries on which Commerce has suspended liquidation cannot be liquidated until Commerce instructs CBP, so the CAPE mechanism cannot reach them. Wait for the relevant administrative review to conclude. The IEEPA refund right is preserved by the suspension itself; no protest is needed. The Tandom AD/CVD catalog at compliance.tandom.ai/adcvd-catalog tracks the active orders and the status of each one's liquidation suspension.
Reconciliation (Type 09) entries
CBP has not stated whether Phase 2 will cover reconciliation entries directly or whether they will need a separate mechanism keyed to the reconciliation cycle. Importers with significant Type 09 IEEPA exposure should contact their CBP Account Manager for guidance and preserve any 1514 protest deadlines on the underlying flagged entries.
Common pitfalls
Filing CAPE for entries you did not file.
A different broker (even one currently working with the importer) cannot file CAPE on entries they did not originally file. ACE rejects the entries at upload. The original filer has to file, period. If the original broker is no longer in business, the IOR can file directly under their own ACE role.
Forgetting to add an ACH account before submitting.
CBP accepts the declaration without an ACH account on file but holds the disbursement until one is added. Adding the account post-acceptance can add two to four weeks. Confirm the account is in ACE before clicking submit.
Mixing Section 122 entries into the CSV.
Entries dated February 24, 2026 onward paid Section 122, not IEEPA. They are not refundable under CAPE, and CBP rejects them at acceptance. Filter the CSV by entry date before upload.
Bundling AD/CVD-suspended entries.
AD/CVD entries with Commerce-suspended liquidation get rejected at acceptance with a reason code. They are not eligible for CAPE Phase 1 because CBP cannot liquidate them without Commerce instructions. Pre-filter against the active AD/CVD catalog.
Splitting a CSV at the wrong boundary.
Files larger than 9,999 entries must be split, but the split should preserve per-IOR groupings where possible to keep the ACH disbursement clean. Splitting alphabetically by entry number can fragment a single IOR's refund across two declarations and make reconciliation harder.
Missing the 180-day protest clock on liquidated entries.
Phase 2 has no committed date. Letting the 180-day 19 USC 1514 protest window lapse on a finally liquidated entry forecloses the refund right. File the protest first and let Phase 2 sort it out later.
Treating MPF and HMF as refundable.
User fees were not affected by the IEEPA ruling. Don't subtract MPF or HMF from the refund estimate; they stay paid.
Counting Section 232 and Section 301 layers as refundable.
Only Chapter 99 codes 9903.01.*, 9903.02.*, 9903.96.01, and 9903.96.02 are IEEPA. Section 232 (9903.81.*, 9903.85.*, and the new derivative codes) and Section 301 (9903.88.*) stayed in force. The Tandom calculator splits the per-line duty stack by authority so the IEEPA-only portion is unambiguous.
Double-claiming through an open drawback.
The same dollar cannot be refunded twice. Resolve any open drawback claim that touched the IEEPA-paid duty before including the entry in CAPE.
Glossary
- ACE Portal
- CBP's Automated Commercial Environment, the production system for entry filing, post-summary corrections, and CAPE Declarations. URL: ace.cbp.gov.
- ACH Refund Account
- Bank account on file in ACE that CBP uses to disburse refunds. Required to be in place before CAPE submission or disbursement is held.
- CAPE Declaration
- The CSV-based filing in ACE that requests refunds for up to 9,999 IEEPA-paying entries at once. Phase 1 launched April 20, 2026.
- Consolidated Administration Processing Entries
- The full name of CAPE. The mechanism's purpose is to consolidate per-entry IEEPA refund work into a single declaration.
- Final liquidation
- CBP's official determination of duties owed under 19 USC 1500. After 90 days, liquidation becomes the binding answer unless protested under 19 USC 1514.
- IEEPA
- International Emergency Economic Powers Act, 50 USC 1701 et seq. The Supreme Court ruled in Learning Resources (Feb 20, 2026) that IEEPA does not authorize tariffs.
- 9903.01.* and 9903.02.*
- The two main IEEPA Chapter 99 code families. 9903.01 covered country-specific tariffs (Mexico, Canada, China, Hong Kong, plus the 10 percent reciprocal baseline at 9903.01.25). 9903.02 covered the country-specific reciprocal tariffs from April and August 2025. Both are CAPE-refundable.
- 9903.96.01 and 9903.96.02
- Companion IEEPA codes that covered low-value China and reciprocal-tariff postal shipments. Also CAPE-refundable.
- Phase 1
- The April 20, 2026 launch covering unliquidated entries and entries within 80 days of liquidation. Roughly 63 percent of IEEPA-paying entries.
- Phase 2
- CBP's stated future expansion of CAPE to finally liquidated entries. No committed launch date as of May 2026.
- 19 USC 1501
- CBP's authority to voluntarily reliquidate within 90 days of original liquidation. Phase 1 piggybacks on this for recently-liquidated entries.
- 19 USC 1505
- Statutory interest authority. CAPE refunds include interest from the deposit date to the refund date at the IRS underpayment rate.
- 19 USC 1514
- Protest authority. The mechanism to challenge a final liquidation; must be filed within 180 days. Used to preserve refund rights on entries excluded from Phase 1.
- Section 122 surcharge
- The 10 percent temporary import surcharge under 19 USC 2132 that replaced IEEPA effective February 24, 2026, authorized by Proclamation 11012. Expires July 24, 2026 absent congressional extension. Not refundable under CAPE.