IEEPA Refunds Update: What U.S. Importers Need to Do in ACE Before Filing a CAPE Declaration

Executive Summary 

CBP’s IEEPA refund process is no longer a wait-and-see story. It is now a workflow story. Beginning April 20, 2026, Phase 1 CAPE Declarations can be filed in ACE. However, refunds will only move if the filer has the right portal access and the receiving party has a valid ACH setup in place. For manufacturers, retailers, and other U.S. importers, the next step is simple: get your records, permissions, and refund instructions lined up before cash gets delayed. 

Intro

Nobody on the shipping side wakes up excited about refund guidance. You wake up to a controller asking whether those tariffs can come back this quarter, a broker asking who can get into ACE, and three people forwarding the same CBP FAQ like it answers anything. 

That’s where IEEPA refunds sit right now. The opportunity is real, but so is the chance to fumble it for mindless reasons. Wrong ACH setup. Missing ACE permissions. Entry data spread across broker reports, ERP exports, and somebody’s desktop file called final_v2.

CBP has made the process clearer, but clearer does not mean easy. Importers still need finance, compliance, and brokers moving in the same direction before a CAPE declaration goes anywhere. So we put together another update to cut through the official wording and get to the important parts: what changed, what needs fixing in ACE, and what your team should do now before a refund turns into one more aging item on the follow-up list.

The Two Steps That Decide Whether Money Moves

If you strip away the policy talk, two gatekeepers control this whole process. First, the filer needs an ACE Portal account because the CAPE Declaration lives there. Second, the importer needs ACH refund enrollment and current banking details in that same portal, or CBP will have nowhere to send the money. That is the part worth circling in red before anyone starts daydreaming about recovered duty dollars.

Get the Right Party Into ACE

IEEPA refunds start with access. CBP says the importer of record or the licensed customs broker that filed the entries must submit the CAPE Declaration, and that filing happens through the ACE Portal. That means your first job is not filing. Your first job is deciding who owns the filing and confirming that person can get into the account without a round of password archaeology. Old permissions, shared logins, and fuzzy ownership will slow this down before the first entry ever gets reviewed.

Get the Refund Path Ready

Filing the declaration only opens the door. ACH setup gets the refund across the finish line. CBP now issues refunds electronically, and importers must enroll for ACH refunds through the ACE Portal and establish or update banking information there before CBP will issue payment. Bad or outdated bank details do not fix themselves in the background. They hold up cash. Teams should treat that setup like a live payment control, because that is exactly what it is.

Additional Things That Matter Right Now

ACE access and ACH setup are the two big gates. After that, a handful of smaller details can still slow IEEPA refunds down, confuse ownership, or leave money sitting in limbo while everyone swears they already handled it.

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• Phase 1 Starts April 20, 2026: That date is a real prep deadline, not a nice idea for later. Teams that wait too long will spend the week chasing entry lists, broker confirmations, and old ACE details they should have checked already.
• Phase 1 Covers Only Recent Entries: During the Phase 1, ACE will only accept unliquidated entries and entries that liquidated within the prior 80 days. Older liquidated entries do not slide into that first batch, so nobody should assume every eligible refund can go in right away.
• Phase 1 Excludes Several Entry Categories: Phase 1 also excludes reconciliation entries (and their flagged underlying entries), entries with open protests, drawback entries, and AD/CVD entries pending liquidation under 19 U.S.C. § 1504(d). These categories will need to wait for a later phase regardless of when they liquidated.
• One CAPE Declaration Can Cover A Lot Of Ground: A broker can include up to 9,999 entries on one CAPE Declaration, even across multiple importers of record. That helps large importers and busy brokers keep volume under control, but only if the entry data is clean before filing starts.
• Accepted CAPE Declarations Stay Locked: ACE does not let filers amend a CAPE Declaration once it is filed and accepted. Late-found entries need a new declaration, which makes pre-filing review a lot cheaper than post-filing regret.
• Open Status Entries Still Count, But Timing Changes: Entries in suspended, extended, or under-review status can still go on the declaration. CBP will issue validated refunds for those entries at liquidation, so finance should expect a staggered payout instead of one clean refund drop.

The FAQs U.S. Importers and Brokers Need Answered ASAP  

Questions quickly pile up once the setup work is clear. Finance wants timing. Brokers want filing rules. Trade teams want to know which entries belong in the first round. Below is the practical heart of our update: eight answers to FAQs that tell you what to do next, without the usual customs fog.

1. How Can Importers and Brokers Prepare Now?

Start with access and ownership. Confirm the ACE Portal account, verify the importer’s subaccount access, check ACH refund instructions, and build the list of entries where IEEPA duties were paid. That prep work saves a lot of back-and-forth later, especially when finance asks for status, and your broker asks for the final entry file for the third time.

2. Who Can File the CAPE Declaration?

CBP limits that role to the importer of record or the licensed customs broker who filed the entries. Additionally, customs brokers that obtain access to the importer's ACE portal can assist with the refund claim filing.  

3. Can Brokers Combine Entries, and Can a CAPE Declaration Be Changed Later?

CBP allows brokers to include up to 9,999 entries on one CAPE Declaration, even across multiple importers of record. That helps with volume. Accepted declarations stay locked, though, so any later-found eligible entries need a new filing.

4. What Happens If a Declaration Is Accepted, Partially Rejected, or More Entries Are Found Later?

ACE issues a CAPE claim number once it validates the file and the listed entries. Rejected entries drop out, and valid entries keep moving. Later discoveries do not get added to the accepted declaration, so teams should expect separate filings when new entries surface.

5. Which Entries Can Be Included Now, and Which Ones Stay Outside Phase 1?

Phase 1 covers entries liquidated within the prior 80 days, plus entries that are suspended, extended, or under review. Several other categories still sit outside the first release while CBP works through later-phase functionality, so nobody should assume every possible entry can go in on day one.

6. Who Gets the Refund, and When Should It Arrive?

CBP sends the refund to the importer of record or to the party the importer designates, including the Form 4811 notify party. Valid IEEPA refunds should generally arrive within 60 to 90 days after CBP accepts the CAPE Declaration, unless a compliance review slows the file down. Suspended, extended, under review, and warehouse entries keep their liquidation status and pay at liquidation.

7. What If the Importer Does Not Have ACE Access or Current ACH Information?

Lack of ACE access blocks proper setup, and stale ACH data blocks payment. Federal Register guidance also makes one point very clear: if CBP approves the refund but cannot deliver it because banking details were never provided or fixed, interest does not keep piling up while that problem sits unresolved.

8. Where Should Readers Go With Unanswered Questions?

Policy questions should go to the IEEPA refunds inbox at IEEPARefunds@cbp.dhs.gov. Filing errors and entry issues should go to a CBP client representative, the ACE Help Desk, or the customs broker handling the work. Everyone loves one last government contact list, but at least this one points to the right desks.

Where Refund Readiness Turns Into Real Work

IEEPA refunds may start as a customs question, but they do not stay there for long. Someone has to reconcile entry history, line up the broker side, confirm payment instructions, clean up supporting records, and keep finance updated on timing. 

That’s the kind of work we handle regularly at Mallory Alexander, because refund prep lives at the point where trade compliance, documentation, and operational follow-through all meet. 

We approach that work the way importers need it approached. Our team supports clients through licensed customs brokerage, trade management and compliance, classification support, and broader customs oversight. We also connect that customs activity to transportation, warehousing, and supply chain execution, which matters when refund prep depends on having the full record in one place instead of being spread across emails, broker reports, and internal files. myMALLORY adds real-time visibility and control, so the process stays organized while the filing plan comes together. 

If CAPE is on your team’s list, contact Mallory Alexander to review your IEEPA refund readiness, confirm ACE and ACH setup, and build a filing strategy before the work starts piling up.