What Is the CAPE Refund Process?
When the Supreme Court ruled certain IEEPA tariffs unlawful earlier this year, a lot of importers heard the headline and assumed a refund check was on its way. It isn’t quite that simple. CBP built a new tool inside the ACE Portal called CAPE, short for Consolidated Administration and Processing of Entries, specifically to handle these refunds in bulk instead of one entry at a time. That’s a real improvement over the old entry-by-entry process, but it’s still a process, and it’s still rolling out in phases, which means not every importer’s situation looks the same right now.
How CAPE’s Phased Rollout Affects Your Refund
The first phase covered unliquidated entries and entries liquidated within 80 days, and a second phase opened things up further to entries flagged for reconciliation. A third phase, covering entries that have been finally liquidated, is still being worked out through the courts, and right now it applies specifically to importers who’ve already filed suit to seek their refund. If you haven’t been following the litigation closely, that distinction matters. Where your entries fall in that timeline determines what you can claim today versus what you may still be waiting on.
Why Your ACE Portal Account Still Matters Here
This is also where we circle back to something we’ve written about before: you need an active ACE Portal account to do any of this. CAPE lives inside ACE, and CBP requires a registered ACH account on top of that before a refund can actually reach your bank. If your ACE access has been sitting unresolved, or you’ve never set up ACH refund banking, that’s the first thing to fix, not the last. We’ve seen importers get their entries reviewed and ready, only to find out the refund itself is stuck because the account plumbing behind it was never finished.
IEEPA Refund or Drawback Claim? Knowing the Difference
The other thing we hear a lot is confusion between an IEEPA refund and a drawback claim. They’re not the same animal. As we put it to a client not long ago, an IEEPA refund is like building a house: there’s a clear process, a flat consult fee, and you’re usually looking at your money back in a matter of weeks, with no need to petition customs or file a waiver. Drawback is the Eiffel Tower. It’s a bigger, more technical build, with more paperwork and more moving pieces, and it deserves a different level of attention. Knowing which one actually applies to your entries, sometimes it’s genuinely both, is the first step to not wasting time chasing the wrong process.
Why Importers Leave This Money on the Table
We’ve helped clients recover more than $10 million in CAPE refunds, and the pattern we see most often is importers who didn’t realize they were even eligible until someone who knows the system looked at their entries. That’s often the real barrier, not the paperwork itself, but simply not knowing to ask the question in the first place. A lot of businesses assume that if CBP owed them money, someone would have already told them. That’s not how this works. The refund exists, but claiming it is on you, or on whoever is managing your compliance.
Protest and litigation deadlines are real and they don’t pause for anyone. Liquidated entries generally have a limited window to file a protest, and once that window closes, the path narrows considerably. So entries that qualify now may not qualify later if they sit too long. That’s not a reason to panic, it’s a reason to get someone looking at your specific entries sooner rather than later, especially if you’re not sure which phase of CAPE your situation even falls under.
How We Stay Ahead of a Moving Target
This is also exactly the kind of moving target where responsiveness matters. CBP’s guidance on CAPE has shifted more than once already as the phases have rolled out, and the businesses that stay current are the ones who get their refunds moving instead of sitting in a queue wondering what changed. We watch these updates as they happen so our clients don’t have to track court filings and CBP bulletins on top of running their business.
Every entry we review, every filing status, every update from CBP on your claim, gets tracked in our Monday.com portal, so you’re never left guessing where your refund stands. One system, one partner, no gaps, the same way we handle everything else.
Frequently Asked Questions
What is the CAPE process for IEEPA tariff refunds? CAPE, or Consolidated Administration and Processing of Entries, is CBP’s tool inside the ACE Portal for processing IEEPA duty refunds in bulk rather than entry by entry. It rolled out in phases, and which phase applies to your entries depends on their liquidation status.
Do I need an ACE Portal account to get an IEEPA refund? Yes. CAPE lives inside the ACE Portal, and CBP also requires a registered ACH account before a refund can be deposited. Both need to be active before a refund claim can move forward.
Is an IEEPA refund the same as a drawback claim? No. An IEEPA refund is a more straightforward process with a flat consult fee and a turnaround of a few weeks. Drawback involves more paperwork and a more technical filing process. Some entries may qualify for both, so it’s worth having your specific situation reviewed.
How do I know if I’m still eligible to claim a refund? Eligibility depends on your entries’ liquidation status and where CAPE’s phased rollout currently stands, along with standard protest and litigation deadlines. Entries that qualify now may not qualify later if they sit too long, so it’s worth having them reviewed sooner rather than later.
Find Out What You’re Owed
If you paid IEEPA duties over the past year and you’re not sure whether you’re owed money back, find out what you’re owed. Tell us your situation and we’ll tell you where your entries actually stand.