What is the CAPE tariff refund portal and how does it work?

If you have clients who import goods and paid IEEPA duties, there's a refund opportunity on the table, and the window to act is open now. U.S. Customs and Border Protection (CBP) launched the first phase of the Consolidated Administration and Processing of Entries (CAPE) system April 20, 2026. The system gives importers and authorized customs brokers a direct pathway to recover duties paid under the International Emergency Economic Powers Act (IEEPA), tariffs that the U.S. Supreme Court ruled invalid earlier this year.

According to CBP, CAPE was built to "streamline the submission and processing of valid refund requests for duties imposed under the International Emergency Economic Powers Act (IEEPA)." The system consolidates refunds across multiple entries rather than requiring importers to file separately for each one. For clients with significant import volume, that's a meaningful procedural advantage. Refunds for qualifying unliquidated entries are expected to be issued within 60 to 90 days of CAPE Declaration acceptance, though certain entries may take longer. 

What is CAPE?

CAPE lives inside the Automated Commercial Environment (ACE) Secure Data Portal. It allows importers of record (IORs) and authorized customs brokers to upload a CSV file listing all entries for which they're requesting an IEEPA duty refund.

Phase 1 currently covers certain unliquidated entries and certain entries within 80 days of liquidation. Warehouse entries and certain suspended or extended entries may also qualify, but refunds are generally issued later, at liquidation. More complex scenarios, including reconciliation entries and drawback claims, will be addressed in later phases. One thing clients should understand right away: CBP is not issuing refunds automatically. The importer of record or its authorized broker must submit a CAPE Declaration to request an IEEPA duty refund. Clients can apply for an ACE Portal Top Account with the Importer Sub-Account view here.

What should you be telling importer clients now? 

Many businesses may not realize they're eligible. But you can help them connect the dots between import activity and potential cash recovery. Start by asking whether clients imported goods between the original effective date of each IEEPA action and Feb. 23, 2026. The key indicator is a Chapter 99 Harmonized Tariff Schedule (HTS) code on CBP Form 7501, Entry Summary. If they see HTS codes in the 9903.01 range, those entries likely involve IEEPA tariffs. 

From there, clients need to be organized. CBP recommends that importers and brokers begin compiling "lists of entries on which IEEPA duties were paid." That means gathering entry numbers, CBP Forms 7501, customs broker invoices and statements, ACH payment records, commercial invoices and any supporting import documentation.

Before a refund can be issued, clients must also have an active ACE Portal account with Automated Clearing House (ACH) refund banking information on file. Having ACH set up for duty payments alone is not enough; the account must be enrolled specifically for refunds.

Who is permitted to file for a tariff refund?

Only the Importer of Record (IOR) or the authorized customs broker that originally filed the entries may submit a CAPE Declaration. You cannot file on behalf of clients. Your role is to help clients coordinate with their customs broker or determine whether to file directly.

Duplicate or improperly structured submissions can delay refunds, and data accuracy matters: errors in formatting or entry numbers may result in rejection and require resubmission. 

Tariff refund tax considerations to review  

Beyond the mechanics of CAPE filing, there are substantive tax questions worth reviewing as clients prepare to receive refunds. If a client deducted tariff costs as an ordinary business expense in a prior year, the refund may constitute taxable income in the year received. The same logic applies to inventory costing; if tariff amounts were capitalized into inventory, a refund could affect cost of goods sold (COGS) on prior or current returns.

Clients should retain documentation of how tariff costs were originally treated for tax purposes. That paper trail matters if questions arise later. It's also worth flagging that §232 and §301 tariffs are entirely separate regimes and were not affected by the Supreme Court ruling.  If clients see those HTS codes on their entry summaries, those duties are not refundable through CAPE.

The real bottom line on the CAPE tariff refund portal

CAPE is a real, time-sensitive opportunity for clients who imported goods during the IEEPA tariff period. The refund process won't happen on its own, and firms that help clients move quickly and accurately will deliver real value. Start by reviewing import activity, confirming ACE Portal access and coordinating with customs brokers now.

For full guidance on the CAPE process, visit CBP's IEEPA Duty Refunds page.