News

IEEPA Duty Refunds

Jun 30, 2026

U.S. Customs and Border Protection (CBP) has announced in CSMS #68315804 the introduction of a new electronic procedure for processing refunds of duties paid under the International Emergency Economic Powers Act (IEEPA).

On April 20, 2026, CBP launched Phase 1 of the Consolidated Administration and Processing of Entries (CAPE) tool on the ACE Secure Data Portal. CAPE is designed to significantly simplify and expedite applications for refunds of IEEPA duties, based on court orders and the applicable legal provisions.

CAPE is a centralized framework within the ACE Portal that enables Importers of Record and customs brokers to electronically submit, validate, and process IEEPA refund requests.

Key Features of CAPE Phase 1:

Electronic submission process for valid IEEPA refund requests
Consolidated refunds including applicable interest
Applies only to certain unliquidated entries and entries within 80 days of liquidation (re-liquidation)

If a protest for an IEEPA refund has already been filed and the entries were made within 80 days of liquidation, the importer may withdraw the protest and submit the refund claim via CAPE.

CAPE Phase 2 Implementation Starting June 29, 2026:

CAPE now also accepts entries that are subject to a subsequent customs reconciliation. A reconciliation is a post-clearance settlement and correction procedure for an import declaration (“Entry”).

Importers can apply for IEEPA duty refunds in the CAPE system even if the relevant import entries are scheduled for a subsequent customs reconciliation and this reconciliation has not yet been submitted. CBP recommends, whenever possible, submitting the reconciliation only after CAPE processing has been completed, unless a deadline is approaching. In this case, the submission should be brought forward.

An IEEPA customs refund may not be claimed via a Post Summary Correction (PSC); the PSC is not an acceptable method for filing such a claim.

The term “liquidation” refers to the final calculation or determination of duties owed on imports; this typically occurs approximately 314 days after the import date. However, many importers have found that some of their IEEPA-subject imports were liquidated earlier than 314 days; therefore, every importer should verify the liquidation status of their imports as soon as possible.

Important: A CAPE Declaration and therefore a duty refund request may only be submitted by the Importer of Record (IOR) or the authorized customs broker who filed the entries.

Requirements for IEEPA Duty Refunds:

Importers of Record (IORs) and authorized customs brokers must have an established account in the ACE Secure Data Portal (ACE Portal account)
Refund recipients must use the ACE Portal account to provide CBP with banking information for refunds
IORs and authorized customs brokers must submit CAPE Declarations in the ACE Portal

To support this process, CBP has published a step-by-Step guide that explains how companies can set up and manage electronic refunds in the ACE Portal, including instructions on prerequisites (such as ensuring importer data per Form 5106 is current) as well as depositing and updating banking information in the Portal.

CBP plans to expand CAPE in later phases to cover more complex scenarios and will publish additional guidance at the appropriate time. Further information (including on Phase 1) is available in the Trade Information Notice.