# IEEPA tariff refunds: how to claim them through CAPE

https://geopax.app/blog/ieepa-tariff-refunds-cape

By Shivam Dubey

Published: 2026-10-11
Category: Research

CBP is refunding IEEPA duties with interest, but only when the importer or its broker asks. Here is who can file, which entries qualify today, and when the money arrives.

The courts have ordered CBP to give back the duties it collected under the International Emergency Economic Powers Act (IEEPA). The refunds include interest, but they are not automatic. The importer of record, or the customs broker that filed the entries, has to claim them through a new tool in ACE called CAPE.

This guide covers who can file, which entries CAPE accepts today, how a claim works, and when to expect the money. It reflects CBP guidance as of October 11, 2026.

## Why CBP is paying refunds

On March 2, 2026, the Court of Appeals for the Federal Circuit sent its mandate on the IEEPA duties to the Court of International Trade. Two days later, in Atmus Filtration v. United States, the trade court told CBP to liquidate unliquidated entries without the IEEPA duties and to reliquidate entries whose liquidation was not yet final. It then paused the deadline so CBP could build a tool to handle the volume.

That tool is the Consolidated Administration and Processing of Entries, or CAPE. It went live in the ACE Portal on April 20, 2026. Instead of refunding entry by entry, CAPE removes the IEEPA Chapter 99 lines from each entry, recalculates the duty, and pays the difference with interest, grouped by importer and liquidation date.

[CBP: CSMS 68340863, CAPE deployment](https://content.govdelivery.com/accounts/USDHSCBP/bulletins/412cc7f)

[CBP: IEEPA duty refunds](https://www.cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds)

## Who can file

Only the importer of record, or the licensed customs broker that filed the entries for it, can file a CAPE Declaration. An attorney cannot file one for an importer. A broker can put entries for many importers on one declaration.

Two things must be in place first. The filer needs an ACE Portal account. The party receiving the money, the importer of record or the party it named on CBP Form 4811, needs US bank details on file for ACH refunds, which requires the Importer sub-account in the ACE Portal. Without them a refund can be rejected. If the REV-613 report shows a rejected refund, enroll for ACH refunds in the ACE Portal and tell CBP at frn-achrefundsupport@cbp.dhs.gov; the payment does not resend on its own.

CBP charges no fee for refunds. It warns that scammers are contacting importers while posing as CBP, and that any request for a fee or for financial details is a scam.

[CBP: who can file and ACH refunds](https://www.cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds)

[CBP: CSMS 69570464, rejected refunds](https://content.govdelivery.com/accounts/USDHSCBP/bulletins/4258fa0)

## Which entries qualify today

CAPE is being built in phases. Phase 1 accepts entries that have not liquidated, and entries that liquidated within the last 80 days. The 80-day limit leaves CBP time to reliquidate within the 90-day window the law allows for voluntary reliquidation. Since June 29, 2026, Phase 2 also accepts entries flagged for reconciliation whose reconciliation entry has not been filed yet.

Entries whose liquidation is suspended, extended or under review are accepted, but their refunds wait until they liquidate. CAPE rejects entries that liquidated more than 80 days ago, entries on a drawback claim or an open protest, reconciliation, drawback, duty deferral and temporary importation under bond entries, and AD/CVD entries pending liquidation. Do not file entries where a surety paid any of the IEEPA duties.

If you filed a protest only to get the IEEPA refund and the entry is within 80 days of liquidation, you can withdraw the protest and file the entry on CAPE instead, which is faster. If the protest is suspended, ask your processing center to lift the suspension first.

Since July 7, 2026, CAPE rejects warehouse entries (types 21 and 22). File the warehouse withdrawals instead, since the IEEPA duties were paid on them; CBP refunds them when the warehouse entry liquidates. A warehouse entry accepted before July 7 without its withdrawals will not be refunded, so put the withdrawals on a new declaration.

Since October 6, 2026, Phase 3 accepts entries that liquidated more than 80 days ago, including finally liquidated ones, but only from importers that sued at the Court of International Trade and have an order to reliquidate their entries. CBP tells each plaintiff's counsel when it can file.

For Phase 1 entries, CBP says you do not need to sue to get your refund. On October 8, 2026, the court certified a class of importers that paid IEEPA duties and have not sued, but what that means for their older entries is not settled. If you have entries that liquidated more than 80 days ago, ask your customs counsel how to protect them.

[CBP: CAPE phases and validation errors](https://www.cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds)

[CBP: CSMS 68340863, protests and sureties](https://content.govdelivery.com/accounts/USDHSCBP/bulletins/412cc7f)

[CBP: CSMS 69127837, warehouse entries](https://content.govdelivery.com/accounts/USDHSCBP/bulletins/41ece9d)

[Court of International Trade: Freestyle World v. CBP, class order](https://law.justia.com/cases/federal/appellate-courts/cit/26-01088/26-01088-2026-10-08.html)

## How a claim works

A CAPE Declaration is a CSV file of entry numbers, uploaded on the CAPE tab of the ACE Portal. CBP needs nothing else in the file. Each entry number is 11 characters without dashes, and one declaration holds up to 9,999 entries. If an entry number starts with a zero, put an apostrophe before it so the spreadsheet keeps the zero.

ACE checks the file, then each entry, and drops any entry that fails while it processes the rest. An accepted declaration gets a claim number. It cannot be amended or cancelled, and each entry can appear on only one accepted declaration, so file entries you find later on a new one.

Do not use a post summary correction to ask for an IEEPA refund. File any other corrections first, then the CAPE Declaration. If you plan to claim drawback on the same imports, file the CAPE Declaration before the drawback claim. The ES-003 report in ACE lists entry lines with IEEPA duties, which is a quick way to build the list.

[CBP: CSMS 68340863, filing rules](https://content.govdelivery.com/accounts/USDHSCBP/bulletins/412cc7f)

## When the money arrives

CBP expects to pay valid refunds 60 to 90 days after it accepts a declaration: 45 days for its review, then time for Treasury to send the payment. Entries that are suspended, extended or under review are paid when they liquidate, and warehouse withdrawals when their warehouse entry liquidates.

Interest runs from the date the duty was deposited to the date the entry liquidates or reliquidates, at the rate the IRS publishes each quarter. CBP nets the whole entry at liquidation, so other underpayments on the same entry reduce the refund, and it can offset unpaid debts the importer owes the government.

Track progress in ACE Reports. ES-022 links declarations, entries and refund numbers and splits principal from interest. REV-603 lists refunds paid, and REV-613 lists refunds rejected because the recipient is not enrolled for ACH.

[CBP: refund timing and reports](https://www.cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds)