March 13, 2026
Trade Compliance Update: CBP’s CAPE Refund System Is Taking Shape
CBP’s ACE-based process for IEEPA refunds is moving from concept to execution. Here’s what the system will do, where delays can still happen, and what importers should clean up now.
The legal fight over IEEPA tariffs created the refund opportunity. The next phase is operational.
CBP has told the U.S. Court of International Trade that it is making progress on CAPE, the new system being built inside ACE to automate refunds of certain tariffs imposed under IEEPA. That matters because this is no longer just a court story. It is now a customs operations story, a cash-flow story, and a readiness story.
For importers, brokers, and finance teams, the message is straightforward: the refund path is starting to come into focus, and the companies that prepare early will be in a much better position when claims open.
What CBP Is Building
CBP is structuring CAPE around four connected components inside ACE.
1. Claim Portal
Importers and brokers will submit CAPE Declarations through a portal in ACE using CSV uploads. The system will validate both the file and the entry data inside it, then return error messaging where corrections are needed.
2. Mass Processing
Once a claim passes validation, CAPE will remove applicable IEEPA HTS numbers and rerun the duty calculation on the remaining tariffs. That recalculation is the core engine behind the refund process.
3. Liquidation/Reliquidation Workflow
Accepted claims will move into liquidation or reliquidation, where CBP will recalculate duties, compute interest, and leave room for manual review when necessary. CBP has said this module will run liquidations Monday through Thursday so there is time for review.
4. Refund Module
After liquidation or reliquidation, CAPE will consolidate refunds by importer of record and liquidation date. Where needed, the importer can designate another payee using CBP Form 4811. Refunds will be issued electronically to the bank account on file.
CBP’s current progress estimates show real movement, but not a finished platform. The claim portal is about 70% complete. The mass processing tool is about 40% complete. The liquidation/reliquidation module is about 80% complete. The refund module is about 60% complete.
At launch, CAPE is expected to cover most formal and informal entries involving IEEPA duties, with more complex entry types expected in later phases.
Why Mallory Customers Should Care
The biggest risk here is not missing the headline. It is missing the readiness window.
CAPE is designed to automate refund processing at scale, but automation does not fix bad entry data, inconsistent importer-of-record details, weak internal coordination, or unclear refund-routing instructions. If your affected entry population is messy, the process gets slower fast.
There is also a very practical issue that many companies still overlook: CBP now issues refunds electronically. That means importers and brokers need refund-ready banking information in place. A company can have money coming back and still create its own delay if ACH setup is incomplete or outdated.
And not every entry will move in phase one. Initial functionality is expected to cover most formal and informal IEEPA entries, but more complex scenarios will come later. That makes it even more important to separate likely phase-one claims from entries that may require a different strategy.
This is one of those moments when trade compliance, customs brokerage, and finance need to act like one team.
If you need the broader refund and landed-cost backdrop, our recent posts on Tariff Ruling: Tariffs Overturned, A Calm Plan For What Comes Next and Global Trade and Compliance: Duty Shock, Border Risk, and the New Cost-to-Serve provide the wider context.
What Importers and Brokers Should Do Now
- Confirm that your company has an ACE Secure Data Portal account and that the right users can access it.
- Review the ACE Portal and ACH Refunds FAQs and the CBP ACH refund guidance to make sure bank information is set up correctly.
- Build a working list of potentially affected entries, including entry numbers, HTS data, liquidation status, and importer-of-record information.
- Decide whether refunds should go directly to the importer or to a designated payee using CBP Form 4811.
- Monitor official CBP CSMS updates and be ready to move when CAPE filing guidance is released.
The companies that do this work now will be ready to move when CAPE opens. The ones that wait for final instructions before getting organized will be starting from behind.
Where Does Mallory Alexander Fit In?
This is exactly where Mallory Alexander and our M-PACT team can help.
We support customers with:
- entry population reviews to identify likely refund candidates
- HTS and Chapter 99 validation tied to IEEPA duties
- ACE readiness and ACH refund setup coordination
- importer-broker workflow alignment before claims are filed
- strategy around complex entries involving AD/CVD, drawback, warehouse treatment, or unusual liquidation status
Refund recovery is not just about filing. It is about filing correctly, quickly, and in a way that protects cash flow.
CAPE may begin accepting claims in roughly the next 45 days. That is enough time to get organized, but not enough time to wait.
For companies that want a CAPE readiness check before claims open, Mallory Alexander and our M-PACT team can help identify what belongs in phase one, what needs cleanup first, and where your refund timeline could get hung up.
Back
.svg)
