IEEPA tariff refund process 2026: how the CAPE portal actually pays out

The IEEPA tariff refund process 2026 stopped being theoretical on April 20, when CBP turned on the Centralized Adjustment for Prior Entries (CAPE) module inside ACE. After the Supreme Court invalidated the IEEPA-based duties earlier this year, importers with cash sitting in liquidated entries now have a defined path. Per RSM's portal walkthrough, CBP expects refunds, including statutory interest, within roughly 60 to 90 days of an accepted CAPE declaration. The catch: the rules around what you can submit, and how, are tighter than most teams realize.

What Phase 1 of the ACE CAPE declaration covers

Phase 1 is deliberately narrow. It accepts unliquidated entries subject to IEEPA duties, entries liquidated within roughly 80 days of filing, and certain suspended or under-review entries that will refund upon liquidation. Reconciliation entries and historically liquidated entries are pushed to later phases that CBP says will roll out across 2026. The submission itself is a structured CSV—RSM notes that no information beyond the entry number is required in the file. Maximum 9,999 entries per declaration. Once accepted, the declaration cannot be amended, and an entry can only appear on one accepted declaration. If you submit duplicates, the second declaration gets bounced.

IEEPA refund eligibility hinges on Chapter 99 codes

The system processes refunds against IEEPA-specific HTSUS Chapter 99 lines—not general Chapter 1-97 duty payments, not Section 232, not Section 301. If your broker classified an entry under a Chapter 99 IEEPA code, you have a claim. If they grouped IEEPA exposure under a different mechanism, that entry is outside the CAPE workflow. Pull your ACE entry summaries by Chapter 99 line and reconcile against your duty bill before you build the CSV. The reconciliation is mechanical, but it is the part most importers will get wrong on the first pass because internal duty reports rarely break out IEEPA versus other Section duties cleanly.

Who files: importer of record or broker

Importers of record can file directly. Customs brokers with a valid POA can file on the importer's behalf. CBP has not opened the door to third-party consultants without broker credentials, which means the legal-services tariff refund cottage industry that sprang up after the SCOTUS ruling cannot upload claims for clients without partnering with a licensed broker. For large importers with thousands of impacted entries, the practical answer is to either run the CAPE submission internally if you have an in-house licensed broker, or to push the work through your existing broker on a defined fee schedule rather than letting an outside firm meter you on a percentage of the recovery.

How freight teams should position

Three concrete plays. One: pull every entry summary from January 2025 forward, filter to Chapter 99 IEEPA lines, and segment by liquidation status. That single report tells you Phase 1 versus Phase 2-plus eligibility. Two: reconcile against duty payment records before submission—an entry number on the CSV with no matching IEEPA payment in the underlying entry is a rejected line. Three: do not amend or piggy-back claims. Each entry gets one shot at one declaration, so consolidate first and submit clean. For importers with thin internal data, bill of lading search against shipment history is a useful cross-check on which entries actually carried IEEPA exposure.

Mapping IEEPA exposure across an entry book is the kind of work that benefits from a structured view of HTS lines, country of origin, and applicable duty stacks. Logistic Intel's tariff calculator is built around exactly this kind of duty-stack reconciliation, so importers can see what was paid under which authority before building the refund file.