CBP Announces April 20 Launch of Refund Dashboard for IEEPA Duties
U.S. Customs and Border Protection (CBP) has announced that it will launch the first phase of its electronic refund system for duties collected under the International Emergency Economic Powers Act (IEEPA) on April 20, 2026. Duties imposed pursuant to IEEPA have been the subject of extensive litigation, and CBP has now established an administrative framework to process refunds of IEEPA duties. To manage volume and operational complexity, CBP is rolling out the refund process in phases, with Phase 1 refunds available only to certain unliquidated entries along with entries that have been liquidated within 80 days.
The new functionality—known as the Consolidated Administration and Processing of Entries (CAPE)—will be available through CBP’s Automated Commercial Environment (ACE) Secure Data Portal and will serve as the primary mechanism for requesting IEEPA duty refunds going forward.
Phase 1 of the Refund Dashboard
What to Expect
CBP has confirmed that Phase 1 of the CAPE refund system will go live on April 20, 2026. Once live, parties will be able to submit refund requests electronically through the ACE Secure Data Portal. Importantly, only the importer of record or the authorized customs broker that filed the entry paperwork on behalf of the importer of record may submit refund requests. In other words, if a company paid IEEPA duties but is not listed as the importer of record for the import, that company may not submit a refund request.
CAPE will consolidate refund requests across multiple entries to streamline CBP’s refund payment process for IEEPA duties, including interest. To submit a refund request, eligible parties will need to prepare a “CAPE Declaration,” which should include a Comma-Separated Values (.CSV) file containing a list of all entries for which IEEPA refunds are requested. CAPE Declarations are limited to 9,999 entries, but multiple declarations may be submitted. CBP has indicated that a template CAPE Declaration will be available once the CAPE system goes live.
Eligibility
Entries eligible for Phase 1 of the CAPE refund program include:
- Most unliquidated entries that include duties imposed pursuant to IEEPA authority; and
- Certain entries within 80 days of liquidation, permitting CBP to reverse or adjust the liquidation and recalculate duties.
CBP has indicated that additional entry types—including more complex scenarios such as entries subject to reconciliation, open protests, drawback claims or final liquidation—will be addressed in later phases of this refund process.
Refund Issuance
Refunds will generally be issued within 60–90 days of the acceptance of a CAPE Declaration, absent the needs for further review. Entries with liquidation status of suspended, extended or under review, as well as warehouse and warehouse withdrawal entries will maintain their liquidation status until resolved, and the refund, if validated, will be issued following liquidation.
Refunds will be issued electronically, and importers must ensure that valid banking information is on file in the ACE Portal prior to submission.
Next Steps
Importers that paid IEEPA duties should review their import histories to identify entries that may qualify for Phase 1 processing and confirm that their ACE Portal access and refund payment information are current before the April 20 launch. Additionally, importers should capitalize on CBP guidance by utilizing templates for CAPE Declarations and the step-by-step refund process guides CBP has published. CBP has stated that it will continue to update its IEEPA refund guidance as additional phases of CAPE are deployed with updated functionality to address more complex refund scenarios.
“Liquidation” is a term of art in U.S. customs law, and refers to the process during which CBP makes the final, legally binding determination of the duties, taxes, and fees owed on an import entry. Imports are generally liquidated around 314 days after entry into the United States. Practically speaking, this means that these Phase 1 refunds will only be available for imports entered into the United States more recently.