IEEPA Tariff Refunds Update: What CBP’s CAPE Phase 1 Means for Importers Right Now

CBP’s March 31 update confirmed that IEEPA tariff refunds are getting closer, but they won’t be simple, automatic, or uniform. CAPE, the new ACE-based refund workflow, rolls out in phases. Phase 1 covers roughly 63% of affected entries, focused on unliquidated entries and those within the 90-day voluntary reliquidation window. Accepted declarations may take up to 45 days to process, and electronic refund registration is now a gating requirement. 

The breakdown below helps importers understand what’s recoverable now, what faces delays, and what to prepare before CAPE goes live.

Lord Lays Out How CAPE Will Handle Refund Claims

IEEPA tariff refunds landed on a lot of Q3 forecasts the moment the announcements hit. Brandon Lord’s March 31 update from CBP should prompt a hard revision.

Lord, the agency’s Executive Director of Trade Programs, laid out how CAPE will handle refund claims, and the operational burden sits squarely with importers: 

• Refunds won’t arrive automatically. 
• Every eligible entry demands its own filing. 
• Banking credentials must be registered before the portal opens. 
• Entry data has to survive validation.
• Liquidation status determines who gets paid when.

Scale matters here too. Reuters tallied 53 million IEEPA-affected shipments across 330,000 importers, and all of those claims will run through a system that has yet to process a single live transaction. 

If that doesn’t sharpen your attention on a Thursday afternoon, your coffee needs upgrading.

So, below, we break down Lord’s update with a digestible yet comprehensive breakdown on what he said regarding eligibility criteria, timing risks, and the steps worth taking before CAPE goes live.

What CBP Actually Announced on March 31 About CAPE

CBP gave IEEPA tariff refunds a formal home. CAPE lives inside ACE and runs on four components:

1. Claim Portal — 85% complete
2. Review and Liquidation/Reliquidation — 80% complete
3. Refund — 75% complete
4. Mass Processing — 60% complete

In other words, progress is real but uneven. No component has crossed the finish line, and Mass Processing, especially, still has significant ground to cover.

The bigger takeaway for importers, though, is that the refund question has moved out of legal limbo and into operations. CAPE is infrastructure, which means your compliance team, your broker, and your data all have to be ready before the portal is.

Which Entries Phase 1 Is Most Likely to Cover First

Phase 1 targets roughly 63% of entries where importers paid or deposited IEEPA duties. That’s a meaningful slice, but eligibility and payment speed are two different conversations.

CBP will prioritize:

• Unliquidated entries
• Entries still within the 90-day voluntary reliquidation window (CBP plans to focus on entries liquidated within the preceding 80 days to close processing before day 90)

Phase 1 also accepts entries with liquidation status marked as:

• Suspended
• Extended
• Under Review
• Warehouse and warehouse withdrawal entries

That said, there’s a catch: acceptance into CAPE does not equal a refund on your next bank statement. Entries in suspended, extended, or under-review status still need to complete the standard liquidation process before any money moves. 

Good news, yes. Instant cash, no.

Which Entries Are Still Complicated, Delayed, or Excluded

Not every entry will clear Phase 1. CBP drew firm lines around what the system can handle right now.

Phase 1 excludes:

• Entries flagged for reconciliation
• Drawback claims
• Open protests
• Entries not filed in ACE or lacking ACE liquidation status
• Certain AD/CVD entries pending liquidation instructions

Later phases are expected to add support for:

• Finally liquidated entries
• Reconciliation and drawback scenarios
• Complex interest calculations
• Stronger compliance tools
• Certain non-ABI entries

The practical reality: most importers won’t fall neatly into one category. Some entries will qualify for Phase 1 without issue. Others will sit in a holding pattern until CBP rolls out additional functionality.

That’s why a blanket refund assumption across your full entry portfolio is a fast way to create problems. The smarter move is segmenting entries now by status, age, and complexity so your team knows exactly which ones to file first and which ones need a longer runway.

Why IEEPA Tariff Refunds Are a Cash-Flow, Governance, and Working-Capital Story

Segmenting entries is step one. Knowing what happens after you file is where finance, operations, and leadership all need to pay attention. CBP’s refund process touches every part of the organization that cares about money, data, or decision rights.  

Cash Flow

Once CBP accepts a CAPE declaration, review and liquidation may take up to 45 days. Compliance concerns can stretch that timeline further. For importers carrying significant duty deposits, 45 days (or longer) between filing and receiving funds changes how you forecast, how you accrue, and how you plan margin recovery. Finance teams need visibility into which entries are filed, which are under review, and which are approaching payout.  

Governance

CBP’s system routes refunds to the importer of record or to a party designated on CBP Form 4811. That sounds simple until you consider how many organizations run multiple brokers, split entry responsibility across divisions, or lack clear internal ownership over who controls that designation. The refund belongs to whoever is on file. Leadership needs to confirm that the right people are making those calls before claims go in, not after.

Working Capital

The scale here matters. As of March 26, 26,664 importers of record had completed electronic refund setup, covering 78% of affected entries and roughly $120 billion in principal IEEPA duties or deposits. CBP moved all refunds to electronic processing on February 6, 2026. Importers who haven’t registered banking credentials yet are sitting on recoverable capital with no mechanism to receive it.

What Importers Should Do Now Before CAPE Opens Wider

Finally, CAPE isn’t waiting for your internal workflows to catch up. The portal will accept claims on its timeline, and importers who haven’t organized their entry data, registered banking credentials, and assigned clear ownership will spend weeks sorting out what could have been ready on day one. Below is a readiness checklist that can give you a head start. 

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• Build a Master Entry Inventory: Pull every affected entry and catalog it by entry number, port, importer of record, liquidation status, duty amount, age, and complexity. You can’t file what you can’t find.
• Sort Entries Into Practical Buckets: Separate your inventory into categories that match how CAPE will process them: unliquidated, within the 90-day reliquidation window, suspended/extended/warehouse, and clearly excluded from Phase 1.  
• Confirm Your Electronic Refund Setup Today: ACH and electronic banking credentials need to be registered before the portal opens. Waiting until launch day is the trade compliance equivalent of printing your boarding pass at the gate.  
• Prepare Submission Data in CAPE’s Expected Format: Legal commentary from Snell & Wilmer notes that the claim portal will use CSV uploads. Get your data shaped now so your team can file quickly once the portal accepts live claims.
• Assign One Internal Owner Across Departments: Someone needs to connect customs, finance, procurement, and logistics under a single point of coordination. Refunds that get stranded between departments don’t get filed. They get forgotten.

Where An Integrated Logistics Partner Fits in Your Strategy

IEEPA tariff refunds have moved from courtroom headlines to operational reality. The importers who recover value fastest will know exactly which entries qualify for Phase 1, which ones don’t, who owns the data, where refunds should land, and how to move without creating new compliance exposure. 

CBP’s March 31 update shows real momentum. It also confirms that Phase 1 covers a fraction of the full picture, and the hard work is only now beginning.

That’s where the refund recovery work gets cross-functional, and touches brokerage, freight, warehousing, compliance, and finance all at once. At Mallory Alexander, we operate across every one of those functions as an integrated global logistics provider:

• Entry Eligibility Triage: We help importers sort affected entries by liquidation status, timing, and complexity so your team knows what fits CAPE Phase 1 and what needs a different path.  
• HTS Classification and Duty Review: Our trade management team offers classification review, HTS updates, and duty optimization support. For refund claims, that means validating whether historical entries, tariff overlays, and product coding hold up before you hit submit.
• Brokerage and ACE Filing Readiness: Our licensed customs brokerage services are integrated with transportation and logistics planning, with a focus on risk management and preventing delays. Getting entry data, refund routing, and customs workflows aligned before CAPE volume ramps up is what we do.
• Complex Entry and Warehouse Coordination: Phase 1 now includes warehouse-related entries and some suspended or extended scenarios. Importers need partners who understand how customs activity connects to storage, withdrawals, and downstream delivery. Mallory Alexander’s warehousing, transloading, and distribution capabilities keep that coordination under one roof.
• Cross-Functional Compliance Support: We offer compliance procedure alignment and on-call advisory support for moments when customs, finance, procurement, and supply chain teams all need to work from the same playbook. Misalignment between departments during a refund cycle can cost just as much as regulatory complexity.
  

Ready to get ahead of CAPE? Contact Mallory Alexander today.