How to File an IEEPA Tariff Refund Through the CAPE Portal (Step-by-Step)

How to File an IEEPA Tariff Refund Through the CAPE Portal (Step-by-Step)

Key Takeaways

  • The deadline to file for IEEPA tariff refunds is October 16, 2026, for entries accepted between April 5, 2025, and February 24, 2026.
  • You must file through the CAPE portal using your own ACE importer sub-account, which can take over a month to set up.
  • The core task is to isolate the exact IEEPA duty amounts for each eligible entry and submit them in a correctly formatted CSV file.
  • This refund is separate from standard duty drawback. Other duties on the same entry, like Section 301 tariffs, must be excluded from the CAPE claim but may be recovered separately.
  • An automated service can help prepare and file claims to ensure you meet the deadline and maximize your refund.

The Phase 1 CAPE filing window closes on October 16, 2026. That is a hard deadline — no extensions have been announced, and U.S. Customs and Border Protection (CBP) has given no indication one is coming. If you paid International Emergency Economic Powers Act (IEEPA) duties on entries accepted between April 5, 2025, and February 24, 2026, you have a fixed window to recover 100% of those duties plus interest.

This refund is not automatic; you must file for it. This guide walks through the process: ACE account setup, data preparation, CSV formatting, and submission.

What the CAPE Portal Actually Is

CAPE — Consolidated Administration and Processing of Entries — is a dedicated system CBP built inside the ACE Portal specifically to process IEEPA tariff refund claims. It launched on April 20, 2026, per CBP's official program page.

CAPE is a separate system from the standard ACE Drawback module. It uses a different mechanic: instead of processing claims entry-by-entry, CAPE consolidates all eligible entries into a single bulk declaration for a lump-sum payment. The process does not transfer from standard duty drawback filings. For a direct comparison of the two mechanisms, see our guide on drawback vs. IEEPA refunds.

Before You File: Your Pre-Flight Checklist

Getting the initial account setup and entry data correct is where most delays originate. As one importer noted in a recent logistics forum discussion, "the filing isn't the hard part, it's the ACE setup and data prep that causes the real headaches."

Some importers report waiting over a month for their ACE importer sub-account to be configured, so it is critical to start early.

Complete every item on this list before you access the CAPE portal. Nothing moves forward until these are in place.

  • Active ACE Importer Sub-Account. The CAPE Declaration must be filed under the Importer of Record's own ACE account. A broker or filer account will not work.

    ⚠️ Critical: Setting up a new ACE importer sub-account can take a month or more. If you do not have one, start the application now. Use CBP's ACE Portal Account Application as your starting point.

  • ACH Bank Details in ACE. CBP issues all IEEPA refunds via direct deposit. Without correct ACH banking information in your ACE importer account, CBP cannot pay you. Enroll using CBP's ACH Bank Information guidance.

  • Complete List of Eligible Entry Numbers. You need every entry number for shipments with a CBP acceptance date between April 5, 2025, and February 24, 2026. The CBP acceptance date is the only date that controls eligibility—not the invoice, purchase order, or bill of lading date.

  • Isolated IEEPA Duty Amounts. For each entry, you need the exact dollar amount of IEEPA tariffs. Other duties on the same entry, like Section 301 or base tariffs, must be excluded from the CAPE filing. They may be recoverable separately through standard duty drawback.

Step-by-Step: How to File Your IEEPA Refund Through CAPE

Step 1 — Verify Your ACE Access and ACH Status

Log into the ACE Secure Data Portal. Confirm two things before moving forward:

  1. You are logged into the Importer of Record's sub-account — not a broker account, not a filer account.
  2. Your ACH bank details are on file and active under that account.

If either is missing, resolve it before proceeding. Delays in setting up the importer sub-account are the most common bottleneck.

Step 2 — Pull Your Entry List

Export all entry summaries from your customs management system or from ACE reports. Filter to include only entries where the CBP acceptance date falls between April 5, 2025, and February 24, 2026.

This date range is non-negotiable. Per CAPE error definitions guidance, entries outside this window will be rejected. Using an invoice, B/L, or purchase order date is a primary cause of rejection.

Step 3 — Isolate IEEPA-Specific Duties

For every entry on your list, pull the Entry Summary (CBP Form 7501) and identify the exact dollar amount paid under IEEPA tariffs. If an entry also carried Section 301, Section 232, or base MFN duties, those amounts stay out of the CAPE filing.

This step is where the work gets granular — and where errors that cause downstream rejections are most likely to originate. If your goods from China, for example, were subject to both IEEPA and Section 301 tariffs, those are two separate pools of money. CAPE handles one. Duty drawback handles the other. See our guide on drawback vs. IEEPA refunds for a full breakdown of how the two processes run in parallel.

Step 4 — Build Your CSV Submission File

Format your eligible entry numbers into a .CSV file. Per CBP's CAPE program guidance, each file can contain a maximum of 9,999 entry numbers.

If you have more — and many high-volume importers do — split them across multiple CSV files and submit each as a separate CAPE Declaration. For large claims, this is where things can get messy if data is not perfectly aligned across thousands of entries.

Refer to CBP's Quick Reference Guide for exact formatting requirements. Small errors in CSV structure — header rows, extra columns, wrong delimiters — will trigger rejections.

Step 5 — Submit the CAPE Declaration in ACE

Log into your ACE Portal importer account. Navigate to the CAPE tab. Upload your formatted CSV file to initiate a CAPE Declaration. CBP's system will run an initial validation check on submission.

Upon successful filing, you'll receive a confirmation. Save it. Record the assigned CAPE Claim Number. This is your tracking reference for everything that follows.

Step 6 — Track Status and Respond to CBP Inquiries

Monitor claim status through ACE reports. CBP's projected processing time is 60–90 days from the acceptance of a valid CAPE Declaration to ACH payment, per its official IEEPA refund page.

That clock does not run if CBP issues a notice. If you receive a CF-28 (Request for Information) or CF-29 (Notice of Action), respond immediately and accurately. The 60–90 day timeline pauses until CBP gets what it needs from you. More on this in the next section.

Common Filing Errors That Delay or Reject Claims

These are not edge cases. Each of the following errors is documented in CBP's guidance or appears regularly in importer-reported filing problems:

  • Wrong date used for eligibility. The CBP entry acceptance date controls eligibility — not your invoice, B/L, or purchase order date. Refer to the CBP Error Definitions Guide for specifics on how CBP flags this.

  • Out-of-window entries submitted. Any entry with a CBP acceptance date before April 5, 2025, or after February 24, 2026, will be rejected. Include only entries that fall cleanly inside the window.

  • No ACH information on file. A complete, approved CAPE claim with no ACH details on file goes nowhere. CBP cannot issue payment by any other method.

  • Non-IEEPA duties included in the CAPE claim. Section 301, Section 232, and base MFN duties are not CAPE-eligible. Including them does not inflate your refund — it creates a mismatch that flags your claim for review or rejection.

  • Incorrect ACE account type. The claim must be filed from the Importer of Record's own importer sub-account, not a broker's filer account.

  • CSV formatting errors. Extra columns, header rows, incorrect delimiters, or files exceeding 9,999 entries will cause submission failures. Use CBP's formatting specification exactly as written in the Quick Reference Guide.

  • Claiming CAPE on duties already included in a drawback claim. If a prior duty drawback filing included the IEEPA duty amount for a given entry and that drawback was paid, those duties are not eligible for a second recovery through CAPE.

  • Ineligible entry types. CAPE Declarations will be rejected for reconciliation entries (type 09), drawback entries (type 47), entries with unresolved protests, and entries subject to Antidumping or Countervailing Duties. Screen your entry list for these before submission.

What Happens After You File

Once CBP accepts your CAPE Declaration, it begins internal processing in several stages:

  1. Entry validation. CBP cross-references each entry number in your CSV against its own records to confirm eligibility and duty amounts.

  2. Duty recalculation. The system recalculates what was owed on each entry, removing the IEEPA tariff component from the total.

  3. Liquidation or reliquidation. Entries that have not yet been liquidated will typically liquidate approximately 45 days after the CAPE Declaration is accepted. Previously liquidated entries go through reliquidation, per Aprio's IEEPA process summary.

  4. ACH payment issued. If the claim is clean — no outstanding issues, no missing information, no flagged entries — the refund (100% of IEEPA duties plus interest) is deposited via ACH within the 60–90 day target.

If you receive a CF-28 or CF-29: Do not treat these as rejections. A CF-28 is CBP asking for additional information on one or more entries. A CF-29 is a notice of proposed action — CBP is flagging something before finalizing it. Both require a prompt, accurate response. Your refund clock is paused until you reply. Late or incomplete responses extend your timeline; non-responses can result in denial of the affected entries.

If Your Entries Also Had Section 301 or Section 232 Duties

CAPE only covers IEEPA duties. But the same entry can generate a second, separate recovery if the goods were later exported or destroyed and other duty types were also paid.

Here is how the two processes work together without violating the double-refund rule:

  • CAPE recovers the IEEPA duty portion of the entry.
  • Duty drawback (filed through the standard ACE Drawback module) recovers the Section 301, Section 232, or base MFN duty portions — provided the goods were exported or destroyed after import.

These are different pools of money on the same entry. Claiming one does not disqualify you from claiming the other, as long as you are not claiming the same dollar amount twice. The IEEPA duties refunded through CAPE cannot be included in any subsequent drawback claim.

Recommended sequence: File your CAPE Declaration first. Once that accounting is locked in, file the corresponding drawback claim covering only the non-IEEPA duty amounts. This keeps the records clean and reduces the risk of a CBP inquiry flagging overlap between claims.

For importers with significant China tariff exposure, Section 301 drawback can represent a substantial additional recovery running in parallel to your CAPE filing. See our guide on Section 301 Duty Drawback for specifics, or return to the full comparison in drawback vs. IEEPA refunds.

Preparing for the CAPE Filing Deadline

The October 16, 2026, deadline is firm. For importers with thousands of entries, sorting the data, isolating the correct duty amounts, and formatting the CSV files is a significant administrative task.

We built our platform to automate this process. Our team of licensed brokers uses our proprietary software to analyze your import history, prepare all necessary CBP-compliant documentation, and manage the filing process for both CAPE and any parallel drawback claims. This typically takes 10–15 business days.

Find out what you could recover with a free eligibility assessment.

Frequently Asked Questions

What is the deadline to file a CAPE claim for IEEPA refunds?

The hard deadline for Phase 1 CAPE filings is October 16, 2026. This applies to entries accepted by U.S. Customs and Border Protection (CBP) between April 5, 2025, and February 24, 2026. CBP has announced no extensions, so it is critical to begin the required ACE account setup process well in advance of this date.

How long does it take to get an IEEPA refund after filing?

You can typically expect your refund in 60 to 90 days after CBP accepts a valid CAPE Declaration. This timeline pauses if CBP issues a Request for Information (CF-28). Promptly providing all requested documentation is key to receiving payment within the target window.

Can I file a CAPE claim myself or do I need a customs broker?

You can file directly if you have an active ACE importer sub-account. Because the data preparation can be complex and time-consuming, many importers choose to work with a customs broker or specialized service provider to prepare and manage the filing.

What is the difference between an IEEPA refund and duty drawback?

An IEEPA refund recovers only IEEPA-specific duties through the CAPE portal. Duty drawback is a separate program that recovers other duties, like Section 301 tariffs, on imported goods that are later exported or destroyed. While they can apply to the same entry, they cover different pools of money.

What if my entries had both IEEPA and Section 301 duties?

You can pursue refunds for both. The IEEPA portion is recovered via a CAPE claim, while the Section 301 portion can be recovered through a separate duty drawback claim if the goods were later exported or destroyed. It is critical to file these correctly to avoid claiming the same duties twice.

What is the most common reason CAPE claims get delayed?

The most common delay is not having an active ACE importer sub-account, a process that can take a month or more. Other frequent errors include incorrect CSV file formatting, including non-IEEPA duties in the claim, or using the wrong eligibility dates. Proper account setup is the critical first step.

What if I already filed for duty drawback on these entries?

You must verify that the IEEPA duty amounts were not included in your previous drawback claim. Claiming the same duties twice is prohibited. If your drawback claim only covered other duties (like Section 301), the IEEPA portion remains eligible for a CAPE refund.

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Published on May 14, 2026