IEEPA Refunds Trade Update
On March 9, 2026, U.S. Customs and Border Protection (“CBP”) proposed an administrative program to Judge Eaton at the Court of International Trade to refund tariffs collected under the International Emergency Economic Powers Act (“IEEPA”) with interest. The program, called the Consolidated Administration and Processing of Entries Claim Portal or “CAPE” will be implemented via CBP’s Automated Commercial Environment (“ACE”).
How will I request a refund through CAPE?
CAPE will allow importers and brokers to submit IEEPA refund claims (“CAPE Declarations”) to CBP via a new tab in the ACE portal, which will consist of a list of entries with IEEPA tariffs attached in a Comma-Separated Values (“CSV”) file. CBP will then validate the entry numbers, calculate the refund plus interest, and issue a refund via CBP’s ACH refund program. Make sure to register your IOR number for ACH refunds through ACE.
When will I receive a refund after filing a CAPE Declaration?
Currently, there is no projected timeline for CAPE Declaration processing times or when CBP will complete and implement CAPE.
Who receives a refund?
Refunds will be issued to the designated bank account of the Importer of Record (“IOR”) or a party the IOR has designated to receive refunds on its behalf using CBP Form 4811 (“Form 4811 designee”).
Will CAPE be able to process refunds for every entry in which I paid IEEPA duties?
No. While CAPE is expected to process the majority of formal and informal entries, the following types of entries will be addressed on a later date:
- Unliquidated entries with a liquidation status “Suspended,” “Extended,” or “Under Review,
- Type 03 Entries (Entries subject to antidumping or countervailing duties),
- Warehouse withdrawals,
- Entries designated on a drawback claim, and
- Possibly other entry types, as announced by CBP after the first phase is rolled out.
The CIT has scheduled a status conference with CBP for March 19, 2026, to review CBP’s progress.
What should I do now?
1. Verify and collect entry data where IEEPA tariffs were paid.
2. Sign up for CBP’s ACH Refunds.
3. Monitor entries for liquidation and protest deadlines.
4. Consider filing an action at the CIT.
