Your IEEPA Tariffs May Be Refundable

Authored by: Brett Leibfried — Partner, CPA | Date Published: June 26, 2026

Importers across the country have been absorbing the cost of tariffs imposed under the International Emergency Economic Powers Act (IEEPA). For many businesses, those costs ran deep. In April, the U.S. opened the door for them to get their money back.

The mechanism is called the Consolidated Administration and Processing of Entries (CAPE). It’s not automatic, it’s not simple, and filing errors can cost you everything. But if your company paid IEEPA duties recently, this is the pathway to understanding, qualifying, and recovering them.

What is CAPE and How Does it Work?

Until now, importers had a few options for seeking tariff refunds. You could pursue court action or protest on an entry-by-entry basis, but neither is fast or simple. CAPE is changing that.

Rather than requiring importers to file protests entry-by-entry or initiate court action, CBP built a new tab inside the existing ACE data portal that allows an Importer of Record to submit a single electronic declaration listing all eligible entry numbers.

This new system is called CAPE. It performs automated validation, removes IEEPA-related HTS Chapter 99 codes from eligible entries, and triggers liquidation.

The process is more simplified than that of a traditional protest, but not without complexity. A single error in your CSV file will result in rejection of the entire declaration, requiring full resubmission. That means precision matters as much as speed, and preparation before you file is just as important as the filing itself.

What is Eligible in Phase 1 of CAPE?

CBP is deploying CAPE in phases, and Phase 1 launched April 20, 2026. This first step is intentionally narrow in scope, designed to capture the “cleanest” entries without complications that could delay processing.

Here’s what to know about Phase 1:

Eligible: Unliquidated entries and entries liquidated within the preceding 80 days of CAPE submission. Must include at least one dutiable IEEPA HTS Chapter 99 code.
Excluded: Reconciliation entries, drawback entries, entries subject to antidumping or countervailing duties pending liquidation, entries flagged for compliance review, and certain warehouse entries.
Future Phases: Fully liquidated entries outside the 80-day window, entries under protest, reconciliation, and drawback entries

For most importers, the practical question is: how many of your entries fall within that 80-day window?

CBP has not yet announced timing for subsequent phases, but phase 1 may capture a meaningful portion of your entry exposure if your company imported goods subject to IEEPA tariffs.

A comprehensive assessment of your entry history against the eligibility criteria is a necessary first step before filing anything.

What are the Critical CAPE Prerequisites?

Before you even file a single entry, importers can get tripped up at the first step. CBP has been explicit: refunds will not be issued unless certain conditions are met in advance.

Missing any one of them will delay or forfeit your refund:

Confirm your ACE Portal account: The Importer of Record must have an active ACE Portal account with an “Importer” sub-account before filing begins.
Enroll in ACH for refund disbursement: All CAPE refunds are disbursed electronically via Automated Clearing House, which has a manual setup step inside the ACE Portal for a refund bank account.
Compile and validate your entry list: Pull all entry numbers on which IEEPA duties were paid and make sure they are accurate and properly formatted.
Review pending protests for IEEPA-related entries: If your company filed protests solely to challenge IEEPA duties, CBP has indicated they may be withdrawn and processed through CAPE for faster refund processing.
Understand the offset provision: Refunds may be subject to offsets against other outstanding debts owed to the federal government.

What happens after you submit?

Once refunds begin flowing, the work isn’t done. CAPE issues consolidated payments that cover thousands of entries. Reconciling those payments against original records, adjusting inventory or COGS figures, and correctly allocating refunds to the right accounting period are the next steps you should take if you have large import programs.

What are the Common Filing Errors Importers Make?

The CAPE process sits at the intersection of customs compliance and tax strategy. Getting the most out of this opportunity requires coordinating both.

When CBP processes a CAPE submission, validation happens in two steps: confirming the file itself and checking each individual entry. Entries that fail validation are flagged and excluded from that filing.

To make sure your filed entry gets accepted and scheduled for liquidation, avoid these filing errors:

Banking information not set up in the Importer sub-account
IOR number in the ACE account does not match the IOR number on submitted entry summaries
Including entries that are excluded from Phase 1
Duplicate entry numbers across multiple declarations
CSV formatting errors that fail file-level validation
Failing to monitor refund activity in ACE via the REV-603 Trade Refund report

The pattern behind most of these errors can be traced to the customs and accounting sides of the business not being on the same page/ A well-coordinated approach helps you recover the maximum amount owed while avoiding surprises at year-end. Your broker handles the CAPE filing, and your advisor addresses tax positioning.

But none of this can happen without scheduling a meeting with your CPA.

Why CAPE Timing Matters

Some importers are waiting to see how Phase 1 plays out before filing. This is understandable, but delay has a real cost that compounds over time.

The 60- to 90-day refund clock starts at acceptance, not submission. Every week of delay in account configuration, enrollment completion, and list compilation pushes your refund window back. Flags that emerge during validation require additional time to resolve. If you choose to be a company that waits, your CAPE phase follows a less certain timeline with fewer options.

Here’s how MBE CPAs can help you complete the CAPE process:

Accurate entry data
Proper ACE configuration
Strategic coordination with your customs broker
Clear accounting and tax plan

Our manufacturing team works with importers to assess exposure, coordinate with customs advisors, and help your business capture every dollar it’s owed. Recovering the IEEPA tariff refunds through CAPE can trigger compliance issues.

The importers who recover the most are the ones who move early, carefully, and with a coordinated team behind them. Let us help you create a clear plan of action.

For questions about IEEPA tariff refunds or the CAPE process, contact MBE CPAs directly.