The IEEPA tariff refund process continues to evolve, and U.S. Customs and Border Protection (CBP) recently provided another status update to the Court of International Trade regarding the progress of the CAPE refund system. The update offers new insight into how refund claims are being processed today and what importers may expect in future phases.

The biggest development is that CAPE Phase I is now actively accepting and processing refund declarations. According to CBP, more than 157,000 CAPE declarations had been submitted as of May 22, 2026, with many entries successfully validated and accepted for IEEPA duty removal. CBP has also reported that billions of dollars in potential refunds have already moved through the system.

At the same time, CBP noted that a significant number of submissions are being rejected due to filing errors. Common issues include importer or filer mismatches, invalid entry numbers, and CSV files that do not match the ACE template requirements. CBP has also identified entry-specific issues, such as entries that fall outside the 90-day reliquidation window, entries without an applicable IEEPA Chapter 99 tariff number, or entries that have already been included on a previously accepted CAPE declaration.

Another area receiving increased attention is reconciliation entries. While CBP has not yet announced a formal Phase II rollout or implementation date, the agency recently updated its public FAQ to indicate that it is developing a phased solution for certain entries flagged for reconciliation. According to CBP, importers may want to allow CAPE processing to occur before filing reconciliation entries when possible, although specific guidance will continue to be released as future phases are developed.

The broader legal landscape also remains active. CBP is expected to provide another update to the Court of International Trade in early June, and ongoing litigation and appeals could continue to influence how refunds are processed and which entries ultimately qualify.

One important reminder for importers is that CBP now issues refunds electronically. Companies should verify that their ACH Refund Authorization information is properly established within the ACE Portal, as refund payments can no longer be issued by paper check.

At 721 Logistics, we will continue to monitor CAPE developments, court activity, and CBP guidance as they become available. Our team is working closely with clients to track entry status, review potential refund opportunities, and stay ahead of changes as the refund process continues to evolve.

For current clients, we encourage you to review the detailed compliance updates previously distributed by our Compliance team, including guidance regarding CAPE filings and ACE ACH refund setup requirements. If you need those communications resent, please contact your 721 representative.