U.S. Customs and Border Protection (CBP) has activated the Consolidated Administration and Processing of Entries (CAPE) tool in the Automated Commercial Environment (ACE), creating a formal path for importers to seek refunds of duties imposed under the International Emergency Economic Powers Act (IEEPA). While CAPE is designed to streamline and consolidate refunds, importers retain key responsibilities that must be addressed before any refund can be issued.
Understanding and preparing for those responsibilities is critical to avoiding delays and missed recoveries.
ACE Portal Access is Mandatory
To participate in the CAPE process, an importer (or its authorized customs broker) must have an active ACE account. CBP no longer issues paper checks for duty refunds. All IEEPA refunds issued through CAPE will be paid electronically via ACH. Importers must ensure ACH refund enrollment is completed in ACE with valid banking information.
Entry Accuracy Comes First—CAPE Is Not a Cleanup Tool
Entries must already be accurate and complete before a CAPE declaration is submitted. CAPE does not correct classification, valuation, or importer data errors. Data quality is essential to timely refunds. Importers must review entries prior to submission to CAPE and, if changes are needed outside the refund process, develop a PSC or Protest strategy prior to requesting refunds.
Be Aware of CAPE Exclusions
CAPE Phase I was deployed on April 20th. The initial CAPE phase contains exceptions for several categories of entries including, but not limited to:
- entries flagged for reconciliation
- entries subject to protest
- entries included on a drawback claim
- antidumping/countervailing duty entries.
CBP has not published a schedule of when future phases of CAPE will be rolled out to capture these refunds, but they are required by the CIT to continue progress on the system development.
How Tradewin Supports Importers and CAPE Refunds
Tradewin assists importers by assessing ACE access, supporting ACH enrollment, auditing entries to confirm accuracy prior to CAPE submission, coordinating with brokers, managing post-entry, and creating a holistic strategy for IEEPA refunds. Our approach is intended to maximize recovery, define timelines for actions, and ensure that compliance measures aren’t sacrificed in the pursuit of duty recovery. We’re here to help.
