Key Highlights

System
CAPE (Consolidated Administration and Processing of Entries)
Launch Date
April 20, 2026
Eligible Period
IEEPA entries – Feb 4, 2025 – Feb 24, 2026
Payment Timeline
~45 days from approval; industry estimate 60–90 days
Payment Method
ACH only (electronic transfer)
Mandatory Requirements
ACE account + ACH refund authorization
Program Scale
>330,000 importers, 53 million shipments, >$170 billion total

IMPORTANT

Refunds are NOT automatic. You must file and complete setup in advance.

Legal & Policy Background

  • Feb 20, 2026: U.S. Supreme Court ruled IEEPA does not authorize broad tariff imposition.
  • Mar 2–6, 2026: CAFC & CIT ordered CBP to:
    • Liquidate unliquidated entries without IEEPA duties
    • Reliquidate non‑final liquidated entries
    • Delay immediate effect to develop CAPE automation
  • Apr 13, 2026: CBP bulletin CSMS#68340863 confirms CAPE deployment on Apr 20.

Pre‑Launch Requirements

  1. Create an ACE Portal Account – Verify email on CBP Form 5106 and complete registration.
  2. Enroll in ACH Electronic Refunds – Log into ACE → ACH Refund Authorization → add U.S. bank details.

  3. No U.S. Bank Account?

    Non-resident importers or those unable to set up an ACE account may authorize a customs broker or an appointed third party to receive refunds on their behalf.

  4. Review Entry Data – Check IEEPA‑eligible entries; file protest within 180 days for liquidated entries. Phase 1 priority: unliquidated + recently liquidated (within 80 days) entries.

Standard Refund Process

Step Description
1 Account Setup ACE + ACH refund authorization
2 Data Review Identify eligible entries & confirm protest deadlines
3 File Claim Submit via CAPE portal (automated validation)
4 Approval & Payment CBP review → liquidation → ACH deposit within 45 days

Critical Notes

  • ❌ No automatic refunds – you must file
  • ⏰ 180‑day protest window for liquidated entries
  • 🏦 ACH only – no paper checks
  • 📝 Use Form 4811 if you lack a U.S. bank account
  • 📊 Phased rollout: ~63% entries in Phase 1; remainder (older final liquidations) in later phases

Industry Impacts

  • Corporate Cash Flow: Tariffs exceeding $170 billion (including interest) were refunded, which significantly improved the cash flow situation of importers and facilitated inventory replenishment activities.
  • Supply Chain & Shipping: Boosts US import demand, cargo volumes and freight rates; digitalization raises compliance standards.
  • Trade Policy: Legally corrects unlawful tariffs, reduces uncertainty, and makes refund processes more transparent.
  • Exporters to the US: Stronger importer liquidity supports export orders; cooperate on refund preparation.