April 9th, 2026 – Recent developments in tariffs imposed under the International Emergency Economic Powers Act (IEEPA) are driving significant changes in how duties are processed, refunded, and administered, as U.S. Customs and Border Protection (CBP) rolls out new systems to streamline claims and improve refund efficiency.
At the center of these updates is CBP’s implementation of a new system within the Automated Commercial Environment (ACE) called the Consolidated Administration and Processing of Entries (CAPE). This system is designed to manage the review, recalculation, and refund of IEEPA-related duties. CAPE includes four key components—Claim Portal, Mass Processing, Review and Liquidation/Reliquidation, and Refund—all of which are currently in advanced stages of development.
Phase 1 of CAPE is expected to begin accepting claims by April 20th, 2026, and will initially focus on entries that are either unliquidated or entries liquidated within the preceding 80 days. Importers must enroll in the ACH refund program through their ACE Portal account to receive payments. This phase is projected to cover approximately 63% of affected entries, allowing many importers to begin recovering previously paid IEEPA duties.
A key operational change impacting importers is the transition to fully electronic refunds. As of February 6th, 2026, CBP requires all duty refunds—including those tied to IEEPA—to be issued via electronic funds transfer. Importers must enroll in the ACH refund program to receive payments, and a significant portion of importers have already completed this process, representing the majority of impacted entries.
It is also important to note that not all entries will be eligible in the initial phase. Certain categories—such as entries under protest, reconciliation entries, or those already finalized—will require future system enhancements or alternative legal remedies. CBP has indicated that subsequent phases of CAPE will address more complex scenarios, including finalized entries and additional compliance considerations.
For customers, these developments signal meaningful progress toward the recovery of IEEPA tariffs but also highlight the importance of timely action. Ensuring eligibility, monitoring liquidation status, and completing electronic refund enrollment will be critical steps in maximizing potential refunds as the process rolls out.
As CBP continues to refine CAPE and expand its capabilities, further updates are expected. Businesses engaged in international trade should stay informed and prepared to take advantage of these evolving opportunities.
The full court documents are linked below for further details:
United States Court of International Trade: Order
Should you have any questions, please contact our Import Compliance team or call us at 518-785-6000.
