CBP’s CAPE refund process continues moving forward as the agency begins processing the first IEEPA-related refunds and releases additional operational guidance for importers navigating the evolving process.
The Consolidated ACE Processing Environment (CAPE) was developed to manage large-scale refund requests tied to IEEPA tariff collections, and recent updates indicate the refund process is now actively moving into implementation.
First Refunds Begin Moving Through Processing
CBP has confirmed that the first approved IEEPA refund claims have begun moving through Treasury payment processing as CAPE implementation continues advancing. In its May 12 status update filed with the Court of International Trade (CIT), CBP reported that more than 126,000 CAPE declarations had been submitted since the April 20 launch, with over 86,000 successfully passing validation checks.
Those accepted declarations represent more than 15 million individual entries approved for IEEPA duty removal processing. CBP also confirmed that approximately 8.3 million entries have already been reliquidated without IEEPA duties, representing an anticipated $35.46 billion in refunds and interest.
CBP also noted that interest across the refund pool continues accruing at an estimated rate of approximately $650 million per month while processing remains ongoing.
While processing activity continues increasing, CBP noted that a significant number of submissions are still failing validation requirements, reinforcing the importance of accurate filing data, ACH setup, and proper Importer of Record identification.
Validation Errors and ACH Issues Continue
As the process expands, operational issues are becoming more apparent across the trade community. Common problems include:
- Missing or incomplete ACH enrollment information
- Formatting errors within CAPE declaration submissions
- Entry-level validation failures
- Importer of Record mismatches
- Filing inconsistencies tied to ACE account setup
CBP has repeatedly emphasized that refunds cannot be issued without validated ACH information on file for the Importer of Record (IOR).
Common CAPE Rejection Issues Continue
CBP also identified several recurring reasons CAPE submissions are being rejected or delayed, including:
- Incorrect Importer of Record (IOR) identification
- Entry number formatting errors
- Entries tied to open drawback claims
- Entries associated with open protests
- Surety-paid IEEPA entries, which are currently excluded from CAPE eligibility
One of the most common issues continues to involve mismatched IOR information. CBP reiterated that only the Importer of Record or the licensed broker who filed the entry on their behalf may submit CAPE declarations.
Phase 1 Limitations Still Apply
Importers should also understand that current CAPE processing remains limited in scope. Phase 1 primarily applies to certain unliquidated entries and entries within specific liquidation windows.
As a result, some importers may not yet see all eligible entries available for processing under the current framework. Additional phases and expanded eligibility guidance are still expected.
CBP has not yet announced a timeline for Phase 2 processing, leaving some importers waiting for additional eligibility expansion and guidance.
Approximately 166,000 AD/CVD-affected entries also remain under manual review assessment.
Refund Timing Expectations
CBP guidance currently indicates that valid refund claims may take approximately 60 to 90 days to complete processing after acceptance into CAPE. This timeline includes:
- CBP review and validation
- Liquidation or reliquidation activity
- Treasury payment processing
Processing timelines may vary depending on entry complexity, filing accuracy, and validation status.
Protest Rights Still Matter
Trade advisors continue encouraging importers to carefully monitor protest deadlines, particularly for entries approaching the 180-day protest window. Because CAPE eligibility remains phased, filing protests may still be necessary in some situations to preserve refund rights while additional guidance develops.
CBP Warns Importers About Refund Scams
CBP also issued recent guidance warning the trade community about phishing attempts and scams targeting importers expecting IEEPA refunds.
According to CBP, the agency will never contact importers through unsolicited phone calls or emails requesting banking changes or CAPE declaration modifications. All CAPE-related activity should occur exclusively through the ACE Secure Data Portal.
Importers are encouraged to remain cautious of fraudulent communications tied to refund activity as processing continues.
What Importers Should Do Now
Importers should continue taking proactive steps to prepare for ongoing CAPE activity, including:
- Verifying ACH enrollment in ACE for each IOR
- Reviewing CAPE submission accuracy
- Monitoring liquidation timelines
- Identifying entries approaching protest deadlines
- Staying current on evolving CBP guidance and validation requirements
As implementation continues, importers should expect additional operational updates, filing clarifications, and process refinements from CBP.
References:
CBP IEEPA Duty Refund Guidance
CBP IEEPA Duty Refund Guidance: https://www.cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds
CBP CSMS #68569567
STR Trade Report: https://www.strtrade.com/trade-news-resources/trade-report
