Re-Introduction to ‘CAPE’—What is it and what does it mean?
The Consolidated Administration and Processing of Entries system (CAPE) was established within the Automated Commercial Environment (ACE) by U.S. Customs and Border Protection (CBP) to process refund requests for duties imposed under the International Emergency Economic Powers Act (IEEPA). These tariffs were deemed unlawful by the U.S. Supreme Court in February of 2026, meaning that eligible parties are able to apply for reimbursement.
How it Works
Only Importers of Record or their customs brokers are legally able to request CAPE refunds. This must be done in the ACE system.
The Phased Approach and Where We Stand
CBP has outlined a plan to launch refund capabilities in three phases. Phase 1, which launched on April 20, 2026, focused on a limited set of entry types, including:
- Unliquidated entries
- Entries within 80 days of liquidation (within the reliquidation window)
- Entries with a status of suspended, under review, or extended
- Warehouse entries and withdrawals
The following two phases seek to address what was lacking in Phase 1. On June 9, Susan Thomas, executive assistant commissioner for CBP’s trade office, announced that Phase 2, which seeks to broaden capabilities for entries marked for reconciliation, is set to launch June 29.
After Phase 2 has been properly implemented, Phase 3 will focus on liquidated entries and those entries with an action still pending in court. This is due to the complicated nature of initiating refunds for entries that have surpassed the 90-day reconciliation window. Thomas has indicated that Phase 3 will be ready by the end of July.
CBP continues to advocate for a suspension of the universal injunction for duties under the IEEPA tariffs is necessary to manage the volume of refund requests.
A Look Back at Phase 1
As of June 4, 2026, CBP has completed approximately $22 billion in IEEPA refunds, with over $89 billion in claims accepted for processing. There’s still a long way to go and many more refund categories to address.
How Tradewin Can Help
As Phase 2 and 3 of CAPE are rolled out, Tradewin can work with you to advise on filing timelines, support your reconciliation submission, and assist on PSC composure and protest submissions to support IEEPA refunds.
