CBP's CAPE System: The IEEPA Refund Portal Takes Shape
By Jon Gilman · Published March 12, 2026 · Updated March 15, 2026
Brandon Lord's second declaration to the Court of International Trade reveals exactly how CBP plans to process $166 billion¹ in IEEPA refunds — and what importers need to have ready when it launches.
CAPE Is Under Construction — Not Live Yet
CBP's CAPE system is between 40-80% complete across its four components. The CIT has continued its suspension of immediate refund orders while CBP builds the system. The next progress report is due March 19, 2026. Importers should use this window to prepare their data, verify ACH enrollment, and organize their entry inventories.
What Is CAPE?
In his March 12 declaration filed in Atmus Filtration, Inc. v. United States, Brandon Lord — CBP's Executive Director of Trade Programs — revealed that the new ACE refund functionality is officially named CAPE: Consolidated Administration and Processing of Entries. It's the system CBP is building from scratch to handle the largest tariff refund in U.S. history.
CAPE's Four Components — Build Status
Claim Portal
70% completeA new web-based interface within ACE where filers — importers directly, TariffClaim on the importer's behalf, or their customs broker — submit "CAPE Declarations." Filers upload a CSV file listing all entry summaries with IEEPA duties paid. ACE then runs two sequential validations: file validation (format, filer authorization, data integrity) and entry-specific validation (confirming entry numbers exist in ACE and at least one IEEPA Chapter 99 HTS number was declared). Entries that fail validation are flagged and can be corrected and resubmitted on a new declaration.
Mass Processing
40% completeAutomatically strips IEEPA HTS numbers from validated entry summaries and recalculates duties owed without the IEEPA tariffs. This runs through ACE's existing duty calculation engine — the same system used for normal entry processing — but applied at unprecedented scale across millions of entries.
Review & Liquidation/Reliquidation
80% completeInitiates the liquidation or reliquidation process for entries in accepted CAPE Declarations. Entries are automatically scheduled to liquidate/reliquidate after a set number of days from acceptance, with a window for CBP to conduct manual review as needed. The component updates entry summaries to reflect new duty totals and automatically calculates interest.
Refund
60% completeWhen entries reach their scheduled liquidation/reliquidation date, ACE directs them to a CAPE-specific refund process. Refunds are consolidated by liquidation date and importer of record (or a designated third party via CBP Form 4811). All refunds are issued electronically via ACH — no paper checks since February 6, 2026.
What CAPE Won't Handle (Phase 1)
CBP is taking a phased approach. The initial CAPE launch will exclude the following entry types:
CBP has committed to expanding CAPE in later phases to handle these more complex scenarios, and will release detailed user guides as each phase is completed.
Electronic refunds are mandatory. As of February 6, 2026, CBP no longer issues paper checks. Lord's declaration notes that many importers still haven't completed ACH enrollment — meaning they cannot receive refunds until they do, even after CAPE launches. If you haven't enrolled, this is your most urgent action item.
How the CAPE Filing Process Will Work
Based on Lord's declaration, here's the filing workflow filers should expect — whether the importer, TariffClaim, or a broker:
What Importers Must Do Now
Enroll in ACH Electronic Refunds — Today
This is your single most important action. CBP will not issue paper checks. If you're not enrolled in ACH through ACE, your refund will be rejected even if your CAPE Declaration is accepted. Visit the ACE Secure Data Portal and complete the "ACH Refund Authorization" setup, or have your customs broker do it on your behalf.
Build Your Entry Inventory
CAPE requires a CSV upload of every entry where IEEPA duties were paid. Start compiling this now. You'll need entry summary numbers, HTS classifications, and duty amounts. Critically, IEEPA duties are not always separately stated in entry documents — you may need to calculate and substantiate amounts.
Monitor Liquidation Deadlines
While CAPE is being built, liquidation clocks are still ticking. If entries liquidate during this build period, you may need to file protests within the 180-day window to preserve your rights — don't assume CAPE will handle entries that slip past deadlines.
Coordinate Your Filing Path
CAPE Declarations can be submitted by importers directly, through TariffClaim, or by a customs broker on the importer's behalf. If you work with a broker, make sure they're aware of CAPE and have access to your ACE data. The filers who prepare now will be submitting on day one.
Court Status & What's Next
TariffClaim: The Operating System for IEEPA Duty Recovery
Lord's March 12 declaration makes one thing crystal clear: CAPE is a filing system, not a preparation system. CBP will validate your CSV, strip IEEPA HTS codes, and process refunds — but the burden of identifying every affected entry, calculating IEEPA-specific duty amounts, verifying data accuracy, and generating CAPE-ready CSV files falls on the filer — whether that's the importer, TariffClaim, or the importer's broker.
That's the gap TariffClaim fills. We're the operating system that sits between your ACE data and CBP's CAPE portal — automating the hardest part of the recovery process.
ACE Connection & Auto-Sync
Connect your ACE account once. We continuously sync your entry data, identify every IEEPA-affected entry, and isolate the specific duty lines — even when IEEPA amounts aren't separately stated in your entry documents.
CAPE-Ready CSV Generation
When the Claim Portal launches, you'll need a properly formatted CSV with all affected entries. TariffClaim generates this automatically from your synced data — validated, formatted, and ready to upload on day one.
Liquidation Deadline Alerts
Entries don't stop liquidating while CAPE is being built. We monitor every deadline and alert you when entries need protective protests — so you don't lose refund rights waiting for the system to launch.
Bring Your Own Broker
If you work with a broker, they can submit your CAPE Declaration on your behalf. We give them a dedicated dashboard to manage your claims — and all their clients' claims — with pre-built filing packets, deadline tracking, and CAPE Declaration exports. You can also submit directly or with TariffClaim.
Phase 1 Exclusion Tracking
CAPE won't handle AD/CVD entries, suspended liquidations, or FTZ withdrawals in Phase 1. We flag which of your entries fall into these categories so you and your counsel can pursue alternative recovery paths.
End-to-End Visibility
From IEEPA exposure calculation to CAPE Declaration submission to refund receipt — track every entry's journey through the recovery process in one dashboard.
The Bottom Line
CAPE is the filing system. TariffClaim is the operating system. CBP is building the portal — but it expects you to show up with a clean, validated CSV of every affected entry, correct ACH enrollment, and accurate duty calculations. The importers who recover first will be the ones who use this build window to get organized. Connect your ACE account to TariffClaim today, and when CAPE goes live, you can submit your declaration yourself, have TariffClaim help you file, or let your broker submit on your behalf — either way, you'll be in the queue while everyone else is still pulling data from spreadsheets.
Frequently Asked Questions
What is CBP's CAPE system for IEEPA refunds?
CAPE (Consolidated Administration and Processing of Entries) is CBP's four-component ACE portal for processing $166 billion in IEEPA tariff refunds. It includes a Claim Portal, Mass Processing engine, Review and Liquidation workflow, and Refund Distribution module.
When will CBP's CAPE refund system be ready?
As of March 12, 2026, CAPE components range from 40% to 80% complete. The Claim Portal is at 70%, Mass Processing at 40%, Review at 80%, and Refund at 60%. CBP has not announced a firm launch date.
Do I need ACH enrollment to receive IEEPA refunds through CAPE?
Yes. CBP stopped issuing paper refund checks on February 6, 2026. ACH enrollment through your ACE account is mandatory — without it, your refund will be rejected even if your CAPE Declaration is accepted.
CAPE Is Coming. Be Ready When It Arrives.
Connect your ACE account, map your IEEPA exposure, and generate your CAPE-ready filing data — all for free.
Free & confidential. No credit card required.
Related Reading
Claim Portal at 73%, refund consolidation under test, and ACE validations nearing completion.
Brandon Lord's March 6 declaration revealing the 7-step refund mechanism affecting 330K importers.
Disclaimer
This page is for informational purposes only and does not constitute legal advice. TariffClaim is not a law firm. The information presented reflects our analysis of Brandon Lord's March 12, 2026 declaration filed with the U.S. Court of International Trade in Atmus Filtration, Inc. v. United States, and publicly available reporting on the same. The CAPE system described herein is under development and not yet operational. CBP's proposed process, timeline, and scope remain subject to change. Consult with qualified trade counsel for advice specific to your situation.