| IEEPA Tariff Refunds Move Forward Under CAPE Phase I, with ACE Tracking Reports Now Available On April 20, 2026, U.S. Customs and Border Protection (“CBP”) announced the activation of Phase I of the Consolidated Administration and Processing of Entries (“CAPE”) for IEEPA tariff refunds. CAPE Phase I is limited to certain unliquidated entries and certain entries liquidated within 80 days of the CAPE claim submission date. CBP’s guidance provides 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.” According to the CIT’s April 28, 2026 Order, refunds have been approved for 21% of the entries with IEEPA duties attached, but only 3% have been liquidated. Although importers have reported receiving limited refunds, the first wave of wholesale refund payments is expected on or about May 11, 2026. CBP has published guidance on how to monitor CAPE refunds via the Automated Commercial Environment (“ACE”). See CSMS # 68536553 of May 4, 2026. We have found the following reports to be the most helpful: |
| ACE report identifier | Description |
| ES-022: CAPE Entry Summary Report | Tracks refunds by entry number, showing total principal and interest per entry. |
| REV-603: Trade Refund Report | Reports all refunds sent to the importer (not just CAPE refunds). |
| REV-613: ACH Rejected Refunds Report | Reports rejected refunds. |
Importers should be aware that, by voluntarily using CAPE, any IEEPA cash deposits will be available to offset amounts owed with respect to other duties. CBP will provide a method for identifying entries that have been adjusted. If CBP takes offsets, and importers want to dispute them, Roberts & Kehagiaras can file protests.
CAPE Phase II will be implemented on a later date. We will continue to monitor the status of CAPE processing and provide further updates as they become available. Stay tuned.
