CAPE Refund Portal: CBP's Automated System for IEEPA Tariff Refunds
What is CAPE? CBP's Automated Refund System
CAPE (Customs Automated Protest and Entry) is CBP's web-based portal purpose-built to process IEEPA tariff refunds at scale. Instead of requiring 333,000 importers to each file individual formal protests under 19 USC 1514, CBP built CAPE to streamline the process into a declaration-based system where importers confirm the IEEPA duty amounts they paid, and CBP cross-references that against its own import records.
Launched via CBP CSMS #68315804 on April 10, 2026, CAPE is the primary mechanism importers will use to recover IEEPA duties paid on goods entered between April 2025 and the SCOTUS ruling date of February 20, 2026. Access it at cbp.gov/cape.
For background on how we got here — the SCOTUS ruling, the $166B refund pool, who qualifies — see our IEEPA Tariff Refund Guide.
CAPE vs. The Traditional Protest Process
Before CAPE, importers who believed CBP assessed incorrect duties had to file formal protests under 19 USC 1514 — a paper-heavy, per-entry process that could take 12-18 months per protest. For the IEEPA situation (millions of entries, hundreds of thousands of importers), the traditional process would have collapsed under its own weight.
CAPE solves this by replacing individual protests with a bulk declaration model:
| Aspect | Traditional Protest | CAPE Portal |
|---|---|---|
| Filing method | Individual written protest per entry | Online declaration via cbp.gov/cape |
| Per-entry requirement | Yes — separate protest per entry | Bulk declaration — multiple entries in one filing |
| Filing fee | $30-$250 per protest | Free (no user fee for refund declarations) |
| Processing time | 12-18 months typical | CBP has not published timelines; scale-driven |
| Legal representation | Often requires counsel | Broker can file with power of attorney |
| Interest | 19 USC 1505(b) — statutory interest owed | Same — interest accrues per entry |
The Supreme Court's February 20, 2026 ruling invalidated all IEEPA tariffs. CBP faced the administrative challenge of refunding duties on 53 million entry summary lines across 333,000 importers of record. A traditional per-entry protest process was not viable at that scale. CAPE is CBP's solution for processing these refunds at speed.
Phase 1 vs. Phase 2 — What Each Covers
CBP is rolling out CAPE in two phases. Phase 1 launches April 20 and covers the majority of entries. Phase 2 will handle the remainder once CBP establishes the required legal framework.
What "Unliquidated" Means
An entry is unliquidated if CBP has not yet made a final determination on the duties owed. Given the volume of imports and CBP's standard processing timelines, most entries filed in 2025 and early 2026 are likely still unliquidated. Your customs broker or the ACE portal can confirm the status of specific entries.
The Phase 2 Waiting Game
Phase 2 will address the remaining ~37% of entries: those already liquidated by CBP before the SCOTUS ruling. These entries require a different legal framework because they would normally be outside the 180-day protest window. CBP has not announced a Phase 2 launch date. Monitor:
- CBP CSMS messages — subscribe at cbp.gov
- cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds — official IEEPA refund page
- The Trade Stack newsletter — we'll publish Phase 2 updates immediately
Phase 1 and Phase 2 are separate processes. Filing your unliquidated entry claims on April 20 does not affect your Phase 2 eligibility for liquidated entries. Get Phase 1 filed first — you can file Phase 2 separately when it opens.
Eligibility: Which of Your Entries Qualify
To qualify for a CAPE Phase 1 refund, an entry must meet all of the following criteria:
| Criterion | Requirement | Phase 1 | Phase 2 |
|---|---|---|---|
| Entry period | Filed between April 2025 and February 20, 2026 | ✓ | ✓ |
| IEEPA duties paid | Chapter 99 HTS subheadings imposed under IEEPA authority | ✓ | ✓ |
| You are the importer of record | Your name/company on CBP Form 7501 | ✓ | ✓ |
| Entry is unliquidated | CBP has not made final duty determination | ✓ | ✗ |
| Entry is liquidated | CBP has made final duty determination | ✗ | ✓ |
| Within standard protest window | Entry is non-final (protest period still open) | ✓ | ✗ |
How to Find IEEPA Duty Lines on Your Entry Summaries
Look at your CBP Form 7501 entry summaries. IEEPA tariffs were collected under HTS Chapter 99 subheadings that specifically cite IEEPA authority. You are looking for rows in the duty section that:
- Use an HTS subheading in Chapter 99
- Carry a rate imposed under the IEEPA emergency declaration
- Show a duty amount paid between April 2025 and February 20, 2026
If you use a customs broker, ask them to generate a report of all entries containing Chapter 99 IEEPA-related duty lines for the affected period. Most brokers are already preparing these reports for clients in anticipation of the CAPE launch.
Upload your entry data to our IEEPA Refund Analyzer to get a detailed refund estimate with interest calculations. For HTS classification questions on which Chapter 99 codes apply to your products, use our HTS Classifier.
How to Use the CAPE Portal — Step by Step
When the portal opens on April 20, follow these steps to file your IEEPA refund declaration. If you've already organized your entry summaries and identified the IEEPA duty lines, the actual portal submission takes 15-30 minutes for most importers.
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Navigate to cbp.gov/cape and register. Starting April 20, go to cbp.gov/cape. Click "Register" and sign in with your ACE portal credentials. If you don't have ACE access, you can register with your importer of record number (ERN/IRS number). Your licensed customs broker can also register on your behalf if you have granted them power of attorney.
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Organize your CBP Form 7501 entry summaries by entry date. Gather all entry summaries for goods entered between April 2025 and February 20, 2026. Access these through the ACE portal or request them from your customs broker. Organize them chronologically so you can cross-reference against your own records during the declaration process.
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Identify the Chapter 99 IEEPA duty lines on each entry. This is the most time-intensive step. For each entry summary, locate the HTS Chapter 99 duty rows and confirm they are IEEPA-related (imposed under the emergency declaration authority). Note the duty amount paid on each line — this is what you will be claiming back. For large importers with hundreds of entries, your broker's IEEPA duty report will be essential.
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Submit your IEEPA refund declaration on CAPE. The portal will walk you through identifying: (a) your importer of record information, (b) the specific entry summary numbers, (c) the IEEPA duty amounts for each entry. CBP will cross-reference your declaration against its own import records. Do not estimate or round — CBP has exact amounts on file; declaring the correct figures avoids delays.
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Receive your claim reference number and track your status. After submission, CAPE will issue a claim reference number. CBP has not published specific processing timelines. Earlier filers are expected to be processed first due to the volume. Monitor CBP CSMS messages for processing updates. CBP will issue refund payments through your normal payment method on file with CBP.
You have 6 days before the portal opens. Use them. Do not expect to arrive at cbp.gov/cape on April 20 and figure it out in real time — the queue will be long and the data you need takes time to assemble. See the preparation checklist below.
What Happens After You File
Here's what to expect once CBP receives your CAPE declaration:
If your declared amounts differ from CBP's records, CBP will contact you through the CAPE portal. You may need to provide supporting documentation (your copy of the entry summaries). In most cases, CBP's ACE records are the authoritative source — discrepancies usually favor CBP's math. Ensure you are declaring the exact amounts shown on your CBP Form 7501 entry summaries.
Preparation Checklist — Do This Before April 20
The importers who file fastest are the ones who prepared in advance. Complete this checklist now:
| # | Task | Status |
|---|---|---|
| 1 | Confirm ACE portal credentials work (or set them up at cbp.gov) | ☐ Not done |
| 2 | Download all CBP Form 7501 entry summaries for April 2025 – Feb 20, 2026 | ☐ Not done |
| 3 | Identify all Chapter 99 IEEPA duty lines on each entry (or request broker report) | ☐ Not done |
| 4 | Sum total IEEPA duties paid per entry and overall | ☐ Not done |
| 5 | Confirm importer of record number (ERN) on file with CBP | ☐ Not done |
| 6 | Check liquidation status of each entry via ACE portal or broker | ☐ Not done |
| 7 | Coordinate with customs broker on filing strategy and power of attorney | ☐ Not done |
| 8 | For Phase 2 entries (liquidated): separate documentation file, monitor for Phase 2 announcement | ☐ Not done |
Our IEEPA Refund Analyzer can help you estimate your total refund. If you have entry data in a spreadsheet, upload it to get a structured estimate. For questions about which Chapter 99 subheadings apply to your products, use our HTS Classifier. For duty drawback opportunities (related but separate), see our Duty Drawback Calculator.
Frequently Asked Questions
Get CAPE portal updates as they happen
Subscribe to The Trade Stack — we'll notify you when Phase 2 dates are announced and when CBP issues processing updates.
- CBP CSMS #68315804, April 10, 2026 — CAPE portal announcement and Phase 1 filing procedures
- cbp.gov/cape — Official CAPE portal (launches April 20, 2026)
- CBP IEEPA Duty Refunds — Official CBP guidance page
- Learning Resources, Inc. v. Trump, 602 U.S. ___ (2026) — Supreme Court opinion striking down IEEPA tariffs
- 19 USC 1505(b) — Statutory interest on CBP duty refunds
- 19 USC 1514 — Right to protest CBP decisions