On Tuesday, March 31, 2026, CBP announced that it is configuring the Consolidated Administration and Processing of Entries (CAPE) to monitor and provide refunds for IEEPA duties. Here are the four components of CAPE and their current status of completion: 

  • Claim Portal – 85% 
  • Mass Processing – 60% 
  • Review and Liquidation / Reliquidation – 80% 
  • Refunds – 75%  
 CAPE Phase 1 WILL Accept: 

1) Entries With Specific Liquidation Statuses 

  • Entries showing Suspended, Extended, or Under Review status are eligible (including unliquidated entries and entries within the 90-day voluntary reliquidation period). 
  • CBP will strip the IEEPA HTS code and recalculate duties excluding IEEPA. These entries won’t be liquidated through CAPE—they’ll liquidate normally, and IEEPA refunds will be issued at liquidation. 

2) AD/CVD-Suspended Entries  

  • AD/CVD entries can be included if liquidation is suspended pending DOC instructions. 

3) Warehouse Entries 

  • CAPE will remove IEEPA HTS codes for warehouse entries and withdrawals. 
  • Refunds won’t be processed through CAPE—they’ll be issued when the warehouse entry liquidates in the normal cycle. 
 CAPE Phase 1 Will NOT Accept 

1) Reconciliation Entries (or Flagged Underlying Entries)

2) Entries Tied to Drawback Claims

3) Entries With an Open Protest

4) Entries NOT in ACE and… Entries Filed in ACE That Lack a Liquidation Status

5) AD/CVD Entries with DOC Liquidation Instructions Already Issued

Timing! 
  • CBP may take up to 45 days after accepting a CAPE Declaration to review and liquidate eligible entries—longer if compliance concerns arise. 
  • CBP will accept CAPE Declarations containing entries liquidated within the preceding 80 days. 
  • Therefore, if you’re past 90 days, file a protest—but avoid filing within the first 90 days unless necessary. 

 

Our office will continue to closely monitor to keep you informed.

We encourage all importers impacted by the IEEPA tariffs to file a court challenge in the CIT. We believe that doing so preserves the right to receive refunds for IEEPA tariffs paid without having to pursue a long additional post-decision process.

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