IEEPA Refund Status Update

2 April 2026 5 MINS. Read USA

Latest Update

On March 31, 2026, CBP updated the Court of International Trade (CIT) on its progress in developing new ACE functionality, the Consolidated Administration and Processing of Entries (CAPE), for IEEPA refunds.

Claim Portal: 85% Complete
Mass Processing: 60% Complete
Review and Liquidation/Reliquidation: 80% Complete
Refund: 75% Complete

CAPE Acceptance Phases

Phase 1

During the first phase of CAPE, the system will be able to process entries that are either unliquidated or for which the 90-day voluntary reliquidation period under 19 U.S.C. § 1501 has not expired. This covers approximately 63% of IEEPA duty-paid entries. Liquidated entries will only be accepted if they were liquidated within the preceding 80 days.

Also accepted will be entries with liquidation status “Suspended,” “Extended,” or “Under Review,” as well as warehouse and warehouse withdrawal entries.

Entries for which the liquidation status is “Suspended,” “Extended,” or “Under Review.” The Mass Processing component of CAPE will update these entries by removing the Harmonized Tariff Schedule of the United States (HTS) code requiring IEEPA duties and will recalculate the duties owed without IEEPA duties. However, CAPE will not liquidate or process the refund of the IEEPA duties on these entries, which will be liquidated (without IEEPA duties) in the normal course, and the IEEPA duties will be refunded upon liquidation. Entries subject to antidumping and/or countervailing duties (AD/CVD) are included in this scenario if their liquidation is suspended pending instructions from the U.S. Department of Commerce (DOC). Entries subject to AD/CVD will be accepted on a CAPE Declaration and the IEEPA duties will be removed, but CBP will not liquidate or process the refund of the IEEPA duties until it receives instructions from DOC to lift the suspension and liquidate the entries.

Warehouse and warehouse withdrawal entries. CAPE will remove the IEEPA HTS codes for warehouse and warehouse withdrawal entries, but will not liquidate or process the refund of the IEEPA duties on these entries. Instead, the liquidation process for warehouse entries will continue to be performed by CBP in the normal course after all withdrawals have been made and the warehouse entry is ready for liquidation, at which time CBP will process the refund of IEEPA duties.

Phase 2 or Later

Later phases of CAPE will include the acceptance of entries:

Flagged for reconciliation
Designated on drawback claims
For which liquidation is final
Non-Automated Broker Interface entries where no entry summary lines exist.
Covered by an open protest

CBP IEEPA Refund Processing Time

CBP will take up to 45 days from its acceptance of a CAPE Declaration to review and liquidate the validated entry summaries identified on the CAPE Declaration, unless there is a compliance concern necessitating further review.

March 27, 2026

On March 27, 2026, CIT Judge Eaton further amended the IEEPA refund court order to include a provision for entries for which liquidation is final. According to the amendment, the entries shall be reliquidated without regard to the IEEPA duties.

“ORDERED that, with respect to any and all unliquidated entries that were entered subject to IEEPA duties, U.S. Customs and Border Protection is hereby directed to liquidate those entries without regard to the IEEPA duties. Any liquidated entries for which liquidation is not final shall be reliquidated without regard to those duties. Any liquidated entries for which liquidation is final shall be reliquidated without regard to the IEEPA duties. For the avoidance of doubt, nothing in this order addresses issues concerning duty free de minimis treatment under 19 U.S.C. § 1321 that are otherwise before this Court. See Axle of Dearborn, Inc. v. Department of Commerce et al. (1:25-cv-00091-3JP); and it is further ORDERED that the court continues to suspend the Amended Order dated March 20, 2026, ECF No. 49, as amended above, to the extent that it requires immediate compliance.”

March 19, 2026

On March 19, 2026, U.S. Customs and Border Protection (CBP) provided an update to the Court of International Trade (CIT) on the buildout of the IEEPA Refund Portal – CAPE (Consolidated Administration and Processing of Entries).

According to Brandon Lord of CBP, the four components of CAPE are progressing toward completion as follows:

• Claim Portal: 73% complete

• Mass Processing: 45% complete

• Review and Liquidation/Reliquidation: 80% complete

• Refund: 63% complete

Following the update and a closed-door conference, CIT Judge Eaton amended the refund order to encompass all duties imposed by IEEPA, including those imposed on imports from Brazil and India.

The parties also discussed, with no resolution, the reliquidation of entries for which liquidation has become final. Importers should be aware of the remedies available under 19 U.S.C. § 1514 (Protest against decisions of Customs Service).

CBP is ordered to provide a progress report to the court by 12:00 p.m. EDT on Tuesday, March 31, 2026, followed by a closed-door conference that same day.

March 12, 2026

On March 12, 2026, Brandon Lord, Executive Director of Trade Programs at U.S. Customs and Border Protection (CBP), submitted an update to the Court of International Trade (CIT) outlining the agency’s progress on implementing systems for IEEPA refunds by a self-imposed deadline of April 20, 2026.

CIT Judge Richard Eaton stated, “Customs is making satisfactory progress to timely complete the development of a process to issue refunds of IEEPA duties paid, with interest”, and “the suspension of the amended Order dated March 5, 2026, is continued; and it is further ORDERED that Defendant (CBP) shall file, by 2:00 p.m. EDT on Thursday, March 19, 2026, a short report describing the progress Customs has made.”

According to the progress update, new ACE functionality will be called the Consolidated Administration and Processing of Entries (CAPE). The CAPE Claim Portal will be web-based and serve as the entry point for importers and customs brokers to submit IEEPA refund requests (“CAPE Declaration”) to CBP. Once operational, a new tab will be available in both importer and customs broker ACE Portal accounts. Lord explained that the development of this portal is about 70% complete.

CBP is designing CAPE with four integrated components:

• Claim Portal

• Mass Processing

• Review and Liquidation/Reliquidation

• Refund

After filers submit information on entries that included IEEPA tariffs, CBP will use a mass processing program to remove the IEEPA HTS numbers and recalculate duties for any remaining tariffs owed. Development of this part of the process is currently about 40% complete.

Another CAPE component will handle the review and liquidation or reliquidation of entries. The system will schedule entries for liquidation or reliquidation after a set number of days – long enough to allow CBP to conduct a manual review if necessary. This component will also calculate interest. Liquidations will occur Monday through Thursday, rather than the traditional once-a-week Friday schedule. According to Lord, this portion of CAPE is about 80% complete.

The refund module will consolidate refunds by Importer of Record and liquidation date, though IORs will also be able to designate another party to receive refunds on their behalf. Development of this part of the system is approximately 60% complete.

The filing also noted that CBP has finished building CAPE-specific refund processing functions with the ACE Collections framework and is currently conducting performance testing on the CAPE refund consolidated process.

Background

CBP Offers IEEPA Tariff Refund Proposal to CIT

CIT Orders CBP to Liquidate IEEPA Entries

What Actions Should Importers Take?

Establish an Importer ACE Portal Account

Companies without an ACE Portal account:

Contact your NNR representative to add or update the Point of Contact (POC) on your 5106 Importer Record on file with U.S. Customs. The Point of Contact will receive a verification code needed to proceed with creating an ACE Portal account.
Apply for an Importer ACE Portal account using the automated application.

Companies that have an ACE Portal account, but do not have the Importer view:

Complete and submit the New ACE Portal Application (digital form)

Authorize ACH Refunds

Duty refunds are issued only via the new ACH Refund process. If CBP is unable to deliver an electronic refund, solely due to the importer’s or designated third party’s failure to provide CBP with the necessary banking information to effectuate the electronic refund, no interest will accrue under 19 U.S.C. 1505(d). For these rejected refunds, an importer must complete the ACH Refund application and notify CBP’s Refunds Team at frn-achrefundsupport@cbp.dhs.gov to confirm the application’s completion and request that the rejected refunds be issued and delivered to the designated bank account.

Authorizing ACH Refunds is different from the ACH Debit program, which allows Importers to pay U.S. Customs duties and taxes directly from their own bank account. The bank account information from the ACH Debit program does not automatically populate the bank account information in the ACE Portal ACH Refund Authorization section. Ensure ACH Refunds are authorized in the ACE Portal by verifying that bank account information is present.
For more information on how to authorize ACH Refunds, refer to the guidance from CBP: ACE Portal – ACH Bank Information for Electronic Refunds

Download ACE Reports

Identify entries that paid IEEPA duties and the liquidation status.

ACE Report ES-003: Entry Summary Line Tariff Details contains Entry Summary Data to help you determine the amount of IEEPA duties paid.
ACE Report ES-701: Courtesy Notice of Liquidation contains dates of liquidation that will help track the status of your entry.
Customized Reporting is available within ACE Reports.
Guidance on how to navigate ACE Reports is available here: ACE Training and Reference Guides | U.S. Customs and Border Protection

File Protests

Importers with customs entries approaching the end of their protest period (days 91-180 post-liquidation) should consider having their customs broker file a protest for those entries to prevent final liquidation.

Protests must be filed within 180 days after liquidation. Protests are used to challenge a CBP decision or to request a correction to a customs entry.

File Suit at the CIT

Several trade attorneys are recommending that importers to file suit in the CIT to preserve refund rights. Contact your trade attorney for guidance.