What is CAPE?
CAPE — Consolidated Administration and Processing of Entries — is a new four-component system being built directly into CBP's Automated Commercial Environment (ACE). It's the official mechanism through which importers and customs brokers will submit IEEPA tariff refund claims and receive refund payments. CBP is building CAPE because the scale of the refund task (over $166 billion across 330,000+ importers and 53 million entries) exceeds the capacity of normal administrative procedures.
Development Progress
As of the March 12, 2026 progress report filed with the Court of International Trade:
Next CBP progress report: March 19, 2026
Judge Eaton has ordered CBP to file continuing progress reports. The next update should provide additional clarity on launch timing and functionality scope. CBP originally estimated 45 days from March 6 — pointing to approximately April 20, 2026 as a target.
How the CAPE Process Works
Component 1: Claim Portal
The portal is a web-based interface within ACE where importers and brokers submit "CAPE Declarations" — refund requests. You'll upload a CSV file listing the entry summaries for which you're requesting IEEPA tariff refunds. ACE will then run two layers of validation: file-level checks (formatting, submitter authorization, file integrity) and entry-specific checks (confirming the entry exists in ACE and contains IEEPA HTS Chapter 99 numbers).
Access requirements: Both importers and licensed customs brokers with active ACE Portal accounts can access CAPE. Filing permissions are expected to mirror existing ACE entry summary access levels.
Component 2: Mass Processing
Once your CSV passes validation, the Mass Processing component automatically strips IEEPA HTS Chapter 99 numbers from each validated entry and recalculates the duties as if the IEEPA tariffs had never been declared. Standard ACE duty calculation validations then run against the recalculated amounts.
Component 3: Review & Liquidation/Reliquidation
Entries from accepted CAPE Declarations are scheduled for liquidation or reliquidation on a specified timeline. CBP retains the ability to conduct manual review during this period. This component updates the underlying entry summaries with new duty totals and automatically calculates interest owed.
Component 4: Refund
The Refund component consolidates payments by liquidation/reliquidation date and importer of record (or a designated payee via CBP Form 4811). Refunds are issued electronically to the designated bank account via ACH. No paper checks — CBP moved to all-electronic refunds as of February 6, 2026.
CSV File Requirements
Your CAPE Declaration will be submitted as a Comma-Separated Values (CSV) file containing a list of entry summaries. While CBP hasn't published final formatting specifications yet, here's what we know about the expected format based on the March 12 declaration and existing ACE data standards.
Expected CSV Format
# Expected CAPE Declaration CSV format (based on CBP declaration) # Final specifications pending CBP user guidance entry_number,entry_type,entry_date,port_code,importer_of_record,hts_number,ieepa_duty_amount EX1-2345678-9,01,2025-04-15,2704,12-3456789,9903.01.25,45230.00 EX1-3456789-0,01,2025-06-22,2704,12-3456789,9903.01.25,23100.50 EX1-4567890-1,01,2025-09-10,1001,12-3456789,9903.01.30,67890.25
Key data points to compile now: Entry summary identifier numbers, entry types, dates, port codes, importer of record numbers, HTS Chapter 99 classification numbers for IEEPA duties, and estimated duty amounts paid.
Two-Layer Validation
CAPE validates your submission at two levels. File-level failures reject the entire file; entry-level failures only affect individual entries.
| Validation Layer | Checks | If Failed |
|---|---|---|
| File-Level | CSV formatting and integrity, submitter identity and authorization, file completeness | Entire file rejected |
| Entry-Level | Entry exists in ACE, IEEPA HTS Chapter 99 numbers present, entry summary data matches | Individual entry rejected; file continues |
⚠ Common Errors to Avoid
Trade law firms have already flagged these frequent mistakes: confusing IEEPA tariffs with Section 232 or 301 duties (only IEEPA is refundable), using incorrect HTS classification numbers, submitting entries where the importer is not the filer or an authorized representative, and including entries whose liquidation status falls outside CAPE's current scope.
Phase 1 Exclusions
CAPE's first deployment will handle most formal and informal entries, but certain complex entry types will initially be excluded. CBP plans to add these in later phases.
If your entries are excluded from Phase 1
CBP has indicated these entry types will be addressed in later CAPE phases. In the meantime, filing a CBP protest or CIT lawsuit preserves your refund rights. See our Refund Process Guide for all available pathways.
What to Do Now — Before CAPE Launches
Verify your ACE Portal access
Confirm you have an active ACE Portal account at ace.cbp.dhs.gov. If your customs broker manages ACE on your behalf, confirm all importer account linkages are current. Outdated designations can delay or misdirect refunds.
Enroll in ACH refunds
Since February 2026, CBP only issues electronic refunds. Register for ACH if you haven't already. Interest does not accrue on undelivered payments for unenrolled parties.
Compile your entry data
Identify all entry summaries with IEEPA HTS Chapter 99 numbers. Organize them by liquidation status. Calculate total IEEPA duties paid per entry. Have this data ready in CSV format so you can submit immediately when CAPE goes live.
Separate IEEPA duties from other tariffs
Many imports had stacked tariffs — IEEPA duties on top of Section 232 or Section 301 tariffs. Only the IEEPA portion is refundable. Ensure your CSV only claims IEEPA amounts.
Prepare CBP Form 4811 (if applicable)
If a third party (such as a customs broker, claim buyer, or litigation funder) will receive refund payments on your behalf, you'll need to file Form 4811 designating them as payee.
Monitor CBP guidance
CBP will publish detailed user instructions before CAPE launches. Bookmark this page — we'll update it as new guidance is released.
Get ahead of the queue
When CAPE launches, there will be a rush of claims from 330,000+ importers. Importers with data pre-compiled and validated will be first in line. The refund component processes payments in order of liquidation/reliquidation date — but having a clean, validated submission avoids rejection delays.
Need help preparing your CAPE submission?
We'll audit your entries, separate IEEPA duties from other tariffs, compile your CSV, and ensure your data is ready for submission the day CAPE launches.
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