CAPE System and IEEPA Refunds: Your Questions Answered

CBP‘s new Consolidated Administration and Processing of Entries (CAPE) system is generating a lot of questions—and for good reason.

If your company imports goods subject to IEEPA-related tariffs, there may be refund dollars available to you. But the process requires organized data, a properly configured ACE account, and a clear understanding of what qualifies—and what doesn’t.

At Western Overseas, we’re already helping importers review entries, evaluate eligibility, and navigate the CAPE filing process with confidence. Below are the questions we’re hearing most often—answered in plain English.

The Basics

What is the CAPE system?

CAPE stands for Consolidated Administration and Processing of Entries. It is a new tool within CBP’s ACE Secure Data Portal that allows importers and licensed customs brokers to submit bulk refund claims for certain duties imposed under the International Emergency Economic Powers Act (IEEPA).

Instead of filing refund requests one entry at a time, eligible companies can submit large batches through a single CAPE declaration—up to 9,999 entries per filing.

Why did CBP create CAPE?

CBP developed CAPE in response to the high volume of refund activity tied to ongoing legal and regulatory challenges surrounding certain IEEPA tariffs. The system is designed to reduce administrative burden, simplify submissions, and improve processing efficiency for high-volume claims.

Does CAPE apply to all tariffs?

No—and this is one of the most important distinctions to understand before assuming you qualify.

CAPE currently applies only to certain qualifying IEEPA-related duties. It does not apply to:

• Section 301 tariffs
• Section 232 tariffs
• Section 122 tariffs
• Standard antidumping or countervailing duties

Many importers are managing multiple tariff programs simultaneously. Not every refund pathway runs through CAPE—and assuming it does can create filing errors and missed deadlines elsewhere.

Eligibility and Entry Requirements

Who can use CAPE?

The system may be used by importers of record or licensed customs brokers acting on their behalf.

To file, you must have:

• An active ACE Secure Data Portal account
• Updated CBP Form 5106 information on file

If your ACE account is not active or your Form 5106 information is outdated, that needs to be resolved before filing—not after. More on why that matters below.

Which entries currently qualify?

Phase 1 of the CAPE rollout applies only to:

• Unliquidated entries
• Entries liquidated within the previous 80 days

Importers with older liquidated entries may need to rely on traditional protest procedures depending on eligibility and timing. CBP has not announced a timeline for Phase 2 expansion, so companies with entries outside the current window should not delay traditional protest filings while awaiting expanded eligibility. Both processes can run in parallel where applicable.

How many entries can be included in one filing?

One CAPE declaration can cover up to 9,999 entries, submitted through a bulk-upload .csv file. For high-volume importers, this is one of the system’s most significant operational advantages.

Claim Status Validations: 

• Entry Summary Status must be Accepted 
• Control Status must be CBP 
• Entry must have at least one IEEPA HTS 
• Entry Type cannot be Duty Deferral (08), Recon (09), TIB (23), or Drawback (47) 
• Entry cannot be flagged for Reconciliation or on an Open or Suspended protest 
• CBP is not authorized to reliquidate the entry summary due to the original liquidation date (liquidated entry summaries over 80 days past their liquidation date)

ACE Account Setup and ACH Enrollment — Do This First

This is the step most importers are overlooking—and it’s causing real delays.

Why does my ACE account matter before I file?

If a CAPE declaration has been filed on your behalf and your ACE account is not set up or your banking information has not been added, CBP cannot transmit your refund.

As of May 11, 2026, 1,880 consolidated refunds have not been transmitted to the Treasury because ACH account information has not been provided by the importer of record or its authorized 4811 designee.

That’s not a system error. That’s 1,880 companies waiting on money that’s already been approved—because the ACH enrollment step wasn’t completed first.

Critical: CBP will not reissue a refund a second time if the first transmission fails. And you will not accrue interest during the delay.

If you have not yet set up your ACE Secure Data Portal account or added your bank information, do that now—before any CAPE declarations are filed.

→ Apply for an ACE Secure Data Portal account: https://www.cbp.gov/trade/automated/how-to-use-ace/portal-applying

If you’re unsure whether your account is properly configured, contact our team and we’ll help you verify it.

The Filing Process

Does CAPE automatically issue refunds?

No. The system streamlines submission mechanics, but it does not eliminate the compliance review.

Before filing, importers and brokers still need to:

• Confirm entry eligibility
• Validate tariff applicability
• Ensure entry data is accurate and properly formatted
• Submit supporting documentation in the required format

Bulk filing also increases the importance of data accuracy. A single formatting error in a .csv upload can affect thousands of entries simultaneously—which means a rejected submission, lost processing time, and liquidation clocks that keep running. Pre-submission validation is not optional.

How long will refunds take after submission?

Current expectations suggest refunds may take approximately 2–3 months after submission. Processing timelines may vary depending on claim volume and CBP review activity.

This is another reason ACH enrollment needs to happen before filing—not after. Approved refunds that can’t be transmitted due to missing banking information do not restart the clock.

Tracking Your Refund in ACE

Once a CAPE declaration has been filed, you can monitor refund status and identify any issues using the following ACE reports. CBP has also published training and reference guides to help users run these reports.

→ ACE Training and Reference Guides: https://www.cbp.gov/trade/automated/training-and-reference-guides

ACE Reports to Know:

ES-022: CAPE Entry Summary Report Links CAPE declaration, entry, and refund numbers to help track the refund process. Displays refund amounts separated by principal and interest. This is your primary tracking tool.

REV-603: Trade Refund Report Enables trade users to track CAPE declarations by refund secondary status. Key statuses to understand:

• Sent to Treasury — Treasury has received an approved refund claim
• Treasury Issued — A refund has been issued
• Funds Diverted — Funds have been diverted for an existing bill (occurs after liquidation, before the refund is issued)
• Check/ACH Returned — Refund was rejected due to incomplete ACH enrollment

For help running this report, review the ACE Reports Trade Refund Report Quick Reference Card (QRC).

REV-613: ACH Rejected Refunds Report Provides information on refunds rejected due to incomplete ACH enrollment. If you see rejected refunds here, review CBP’s Replacement Refund Instructions immediately.

REV-615: CAPE Details Refunds Report Builds on REV-603 and provides entry summary-level details associated with CAPE declarations that have been sent to Treasury. Use this for a more granular view of your refund activity.

Security and Fraud Prevention

Are there scams targeting CAPE filers?

Yes—and CBP has issued formal warnings about this.

Because CAPE operates exclusively through the ACE Secure Data Portal, importers should take the following precautions:

• Protect ACE login credentials and never share them informally
• Verify any communication claiming to represent CBP before responding
• Limit unnecessary account access across your organization
• Keep all company and filer information current within ACE, including Form 5106 data

CBP will never ask for your ACE password via email or direct you to a third-party website to verify your CAPE eligibility. If you receive a communication that looks suspicious, verify it through official CBP channels before taking any action.

→ CBP Best Practices for Protecting Your Information Regarding IEEPA Refunds

Questions About Your Refund? CBP Contacts

If you have specific questions about a refund that has already been filed, you can contact CBP’s Revenue Division directly:

Treasury Offset Program: Phone: (317) 298-1392 Email: cbptreasuryoffsetprogram@cbp.dhs.gov

CBP Revenue Division Helpdesk Directory

What to Do Right Now

Even if you’re not ready to file immediately, there are steps worth taking now.

1. Set up and verify your ACE account first Before any CAPE declaration is filed, confirm your ACE Secure Data Portal account is active and your ACH banking information is enrolled. This is the step most importers miss—and it’s the one that holds up approved refunds.
2. Review entry history and liquidation timing Identify which entries may fall within Phase 1 parameters—unliquidated or liquidated within the past 80 days.
3. Confirm tariff applicability Verify that the duties involved are IEEPA-related and qualify under the current CAPE parameters—not Section 301, 232, or 122.
4. Don’t wait on older entries If you have liquidated entries outside the 80-day window, don’t assume Phase 2 will cover them. Pursue traditional protest procedures now where applicable. Deadlines don’t pause.
5. Coordinate with your broker Discuss timing, eligibility, data formatting requirements, and submission strategy. The complexity of a bulk filing increases with entry volume—pre-submission validation is critical.

How Western Overseas Can Help

CAPE introduces automation, but the compliance analysis underneath it still requires careful, experienced review.

At Western Overseas, we help importers:

• Verify ACE account setup and ACH enrollment status
• Determine which entries qualify under current CAPE parameters
• Organize and validate bulk filing data before submission
• Coordinate CAPE filings with traditional protest timelines where needed
• Monitor refund status using ACE reporting tools
• Navigate CBP communications and resolve issues that surface during processing

For companies managing complex tariff exposure across multiple programs, the challenge isn’t just filing the claim—it’s making sure the right entries are included, the data is clean, and the account is ready to receive the refund when it’s approved.

Contact our IEEPA team to review your entry history, assess CAPE eligibility, and ensure your ACE account is ready before your refund is filed.