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IEEPA Duty Refunds: How CBP’s New CAPE Procedure Works for Importers

The U.S. Customs and Border Protection (CBP) is developing the Consolidated Administration and Processing of Entries (CAPE) functionality to streamline the submission and processing of valid refund claims for duties imposed under the International Emergency Economic Powers Act (IEEPA) that are deemed unlawful.

CAPE is designed to consolidate IEEPA duty refunds, including interest. It will be implemented in phases. CBP launched the first phase on April 20, 2026, limited to customs declarations not yet cleared and those cleared no more than 80 days ago.

Registered importers (IORs) and authorized customs brokers must have an ACE Secure Data Portal account (ACE Portal account) to provide CBP with bank account information and submit refund claims.

The CAPE declaration consists of the list of imports for which IEEPA duty refunds are requested. Each CAPE declaration has a limit of 9,999 entries, but multiple declarations can be submitted.

Once the request is validated and accepted, ACE will update the customs declarations in the summary lines of the affected entries, removing the IEEPA Harmonized Customs Tariff Chapter 99 provision and the related IEEPA duties, thus generating an updated version of the entries and a new settlement.

Refunds will be consolidated by IOR or the party designated by the IOR to receive the refunds on its behalf via CBP Form 4811 (“Form 4811 Notification to Party”), and by settlement date.

Valid IEEPA refunds will generally be issued within 60-90 days of acceptance of the CAPE Declaration, unless a compliance issue requires further review by CBP (Customs and Border Protection).

Please note that all IEEPA duty refunds processed by CAPE will be subject to the offsetting of all overpayments and underpayments for the entire declaration, as well as any rerouting of refunds, where necessary and appropriate, to offset any unpaid, legally established debts owed by the importer to the United States.

Giorgia Orsi
giorgia.orsi@mordiglia.it

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