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IEEPA refunds are recoverable. Phase 1 is where the money is moving now.

Importers who paid duties under the International Emergency Economic Powers Act (IEEPA) can now file for refunds through CBP's Consolidated Administrative Protest Environment (CAPE). Phase 1 covers the bulk of actionable entries today, and CBP is working through them on a 45-day processing window.

Watch the Webinar ReplayGet help now →

April Witthoeft, VP of Compliance, walks importers through what is recoverable today, what waits for a later phase, and how to get started. 30 minutes plus Q&A. Watch the on-demand replay anytime.

What is actually happening

IEEPA duties, CAPE filings, and why Phase 1 is the priority window.

Four terms to know, then the phase split, then the clock.

IEEPA
International Emergency Economic Powers Act. The statute under which certain import duties were collected and are now refundable.
CAPE
Consolidated Administrative Protest Environment. The CBP system where IEEPA refund declarations are filed.
HTS
Harmonized Tariff Schedule. The classification of your imported goods that determines if IEEPA duties applied.
ACE
Automated Commercial Environment. The CBP system holding your entry records, which a broker needs access to in order to file.
Phase 1 · File now

The bulk of actionable entries today.

Most importers' recoverable duties sit here. If an entry falls in Phase 1, it belongs in a CAPE filing this cycle.

  • Unliquidated entries
  • Entries liquidated less than 80 days
  • Entries not subject to later-phase exclusions
Phase 2 and later · Queue cleanly

Complex cases that wait for a later phase.

These are still recoverable. They just route through a different process and should not be mixed in with Phase 1.

  • Entries on drawback claims
  • Entries liquidated 80+ days
  • Entries under open protest
  • Reconciliation entries
  • AD/CVD entries pending liquidation under 19 U.S.C. § 1504(d)
45day window
CBP is processing Phase 1 declarations on a 45-day window.Earlier declarations clear before later ones. Importers who wait to act on Phase 1 give up their place in line.

On-Demand Replay · Recorded May 6, 2026

What every importer needs to know about IEEPA refunds right now.

Available now

April Witthoeft walks through Phase 1, Phase 2, and what to do this week.

Recorded May 6, 202630 minutesLinkedIn
What's covered
  1. What IEEPA duties are, and which entries are recoverable
  2. Phase 1 vs. Phase 2 classification in plain English
  3. How the CAPE filing process works from entry analysis to refund
  4. Q&A with April on common importer situations

How M-PACT helps

Two service models, depending on who your broker of record is.

CBP has confirmed that only the original broker or the importer of record can file an IEEPA refund. M-PACT meets you where you are: as your broker of record, or alongside your current broker.

Full Filing Authority

When Mallory is your customs broker of record.

Fit. You already clear entries through Mallory. M-PACT can prepare, file, and track your IEEPA refunds end-to-end.

01
Preparation
Analytical report across your entries. Each is tagged with entry type, entry number, entry date, liquidation date and status, estimated refund amount, assigned recovery phase, and eligibility indicators.
Flat fee $2,500
02
IEEPA Claim Filing
End-to-end CAPE submission support. Declaration creation, CSV uploads, CBP status monitoring, exception resolution.
Hourly, scoped to your entries. 30-minute minimum, 15-minute increments.
03
Post Filing Support
Monthly status report tracking refunds and any CBP entry packet requests.
Hourly, scoped to your entries. 30-minute minimum, 15-minute increments.
Hybrid Filing Authority

When another broker is your broker of record.

Fit. You work with another customs broker. Grant M-PACT ACE access and we can prepare and file across your full book.

01
Preparation
Same analytical report as Full Filing Authority, covering both M-PACT-filed entries and third-party-filed entries. Full book visibility.
Flat fee $3,500
02
IEEPA Claim Filing
End-to-end CAPE submission support. Declaration creation, CSV uploads, CBP status monitoring, exception resolution.
Hourly, scoped to your entries. 30-minute minimum, 15-minute increments.
03
Post Filing Support
Monthly status report tracking refunds and any CBP entry packet requests.
Hourly, scoped to your entries. 30-minute minimum, 15-minute increments.

Which model fits? Choose Full Filing Authority if Mallory is your customs broker of record. Choose Hybrid Filing Authority if you work with another broker and need M-PACT to handle preparation and filing across your full book.

How M-PACT works

Three steps, one clean path.

01

Assess

Entry-level analysis. Every recoverable entry is tagged with its phase designation so Phase 1 money can start moving while Phase 2 cases queue cleanly for later.

02

File

CAPE submissions end-to-end. Declaration creation, CSV uploads, CBP status monitoring, and exception resolution on every filed entry.

03

Recover

Monthly refund tracking, CBP entry packet follow-through, and a clear report of what has been paid, what is pending, and what is next.

Talk to M-PACT

Tell us about your situation and we will walk you through it.

No calendar link, no quiz. A short note to the M-PACT team. We will respond within one business day with an honest read on where you fit and what to do next.

  • Whether your entries are Phase 1, Phase 2, or a mix.
  • Whether we can help directly, or whether you need to go back to your broker of record.
  • What to expect on timing, documentation, and next steps.
Your message routes to the IEEPA mailbox, monitored by the M-PACT team.
Talk to M-PACT

Short form, human reply.

We read every message and route it to the right person on the M-PACT team.

By submitting, you agree to Mallory's privacy policy. Your message routes to the IEEPA mailbox.

Who you are working with

A Licensed Customs Broker and a 100-year-old logistics operator.

Licensed Customs BrokerISO 9001:2015C-TPATInbound Logistics Top 100

April Witthoeft

VP of Compliance

Leads Mallory's licensed customs brokerage and compliance practice. Working with CBP and trade counsel on CAPE filing mechanics since the first guidance dropped.

On-Demand Replay · LinkedIn

30 minutes on what is recoverable and what to do this week.

Open to anyone. Watch the replay on demand.