Recent developments in the IEEPA tariff refund process continue to move forward, with U.S. Customs and Border Protection (CBP) introducing a new system called CAPE (Consolidated Administration and Processing of Entries). While the process is not yet finalized, this marks a significant step toward a structured refund mechanism for importers.
What Is CAPE?
CBP is developing CAPE within the Automated Commercial Environment (ACE) as a web-based portal that will allow importers and customs brokers to submit IEEPA refund claims electronically.
Once implemented, CAPE is expected to:
- Serve as the central platform for submitting refund requests
- Validate entries and recalculate duties
- Support review, liquidation, and refund processing
The system is currently in development, with multiple components already partially completed
CAPE Phase 1
The initial rollout (CAPE Phase 1) will be limited in scope. At a high level, it is expected to focus on:
- Unliquidated entries
- Entries still within the 90-day reliquidation window
- Certain entries under review or extended status
Some entry types will not be included in Phase 1 and may be addressed in later phases as CBP expands the system.
Additionally, once a claim is accepted, CBP has indicated that processing may take up to 45 days, depending on review requirements.
Although this development signals progress, the IEEPA refund process is still not active or finalized, and ongoing legal proceedings and regulatory updates will continue to shape how and when refunds may be issued. If refunds are ultimately approved, they would generally apply to importers who paid IEEPA duties on qualifying entries, with eligibility and timing dependent on final guidance.
At 721 Logistics, we are actively monitoring CAPE developments, court activity, and CBP guidance. We are track entry and liquidation statuses, staying ahead of regulatory changes, and helping position our importers to take advantage of potential refund opportunities as guidance evolves.
For a more detailed breakdown, our Compliance team has shared in-depth updates directly with clients. Please refer to those emails or contact us if you’d like them resent.
As the situation continues to develop, additional updates are expected.