CAPE Launch: What Importers Must Do Now to Recover IEEPA Tariffs
The U.S. Customs and Border Protection (CBP) will launch Phase 1 of the Consolidated Administration and Processing of Entries (CAPE) system on April 20, 2026—marking a major operational shift in how importers recover IEEPA tariffs following recent court decisions. CAPE introduces an electronic, ACE Portal–based process that allows importers to submit refund claims in a consolidated manner, rather than pursuing corrections on an entry-by-entry basis. This is a significant improvement in efficiency, particularly for companies with high transaction volumes, as CBP will remove IEEPA duties, recalculate entries, and issue refunds (including interest) in a streamlined process.
However, Phase 1 comes with important limitations. CAPE is currently restricted to certain unliquidated entries and those within 80 days of liquidation, meaning the window for recovery is narrow and time-sensitive. Importers must also understand that while CBP allows both Importers of Record (IORs) and authorized customs brokers to submit CAPE declarations, the system is operationally tied to filer code validation. In practice, this means many importers—especially those without filer codes or who did not file their own entries—will need to rely on their original filing brokers to submit CAPE declarations successfully.
To take advantage of CAPE, importers should act immediately. First, confirm that your company has an active ACE Secure Data Portal account and that ACH banking information is properly configured to receive refunds. Second, identify all entries that may be eligible under Phase 1, focusing on unliquidated entries and those approaching the 80-day post-liquidation threshold. Third, coordinate with your customs broker to ensure CAPE declarations are prepared and submitted accurately, as validation errors—such as mismatched filer codes or entry data—can delay or prevent processing.
At a strategic level, CAPE should not be viewed as a “wait-and-see” solution. Court developments have made clear that importers are entitled to refunds of IEEPA tariffs, and CBP is moving forward with implementation. At the same time, deadlines tied to liquidation status continue to run. Importers should therefore pursue a parallel strategy: utilize CAPE where applicable, while preserving legal rights through protests for entries that are liquidated but not yet final.
In short, CAPE represents a critical opportunity—but also a compliance exercise requiring coordination, timing, and technical accuracy. Companies that prepare early and align internal teams with their brokers will be best positioned to recover duties efficiently and avoid missed recovery opportunities.