On April 10, 2026, U.S. Customs and Border Protection (“CBP”) published Cargo Systems Messaging Service (“CSMS”) #68315804, confirming that Phase 1 of the process to refund duties paid by importers under the International Emergency Economic Powers Act (“IEEPA”) will launch on April 20, 2026.  Known as the Consolidated Administration and Processing of Entries (“CAPE”), CBP introduced the refund process in a March 12, 2026 declaration to the U.S. Court of International Trade, noting that it will be accessible within the Automated Commercial Environment (“ACE”), CBP’s portal for processing, collecting, refunding, and recording tariffs (see Update of March 13, 2026).

According to the CSMS message, the CAPE is designed to consolidate refunds of IEEPA duties, including interest, rather than processing refunds on an entry-by-entry basis.  The CAPE process begins with the filing of a CAPE Declaration in the ACE by the importer of record (“IOR”) or the authorized broker who filed the entry (or entries) on behalf of the IOR.  Once accepted, CBP will remove the IEEPA Harmonized Tariff Schedule number(s) and recalculate duties without the IEEPA tariffs.  CBP will then review the updated entry and liquidate or reliquidate it, with refunds consolidated by liquidation date and by IOR (or the party designated to receive refunds by the IOR). 

Phase 1 of the CAPE will be limited to “certain unliquidated entries and certain entries within 80 days of liquidation,” while “more complicated [import] scenarios” will be addressed in later phases.

To promote the rollout of the CAPE, CBP has published several resources in addition to the CSMS message, including a 1-page fact sheet about the CAPE, a lengthier CAPE Information Notice, a step-by-step reference guide for using the CAPE within the ACE, and a dedicated webpage on the CBP website.

According to the CAPE webpage’s FAQ section, refunds “will generally be issued within 60–90 days following acceptance of [a] CAPE Declaration, unless a compliance concern requires further CBP review.”  In a March 31, 2026 declaration, CBP indicated that it anticipated processing refunds within 45 days after accepting a CAPE Declaration, absent any compliance concerns (see Update of April 3, 2026).

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Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.

Photo of David M. Schwartz David M. Schwartz

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping…

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.