What Is CAPE and How Does It Help With Tariff Refunds?

The Supreme Court struck down tariffs imposed under the International Emergency Economic Powers Act (IEEPA) in February. That presented two major challenges. For Customs and Border Protection (CBP), the challenge lay in processing refunds for 330,000 importers. For importers, it was about collecting those refunds without weeks of portal errors and rejected filings. CBP’s new CAPE system comes in here, handling these claims at scale.

Unfortunately, the process is not as straightforward as importers would like. There are already complaints about rejections that importers do not understand. However, those who have their customs data organized, especially with tools like Laufer’s PeerPLUS and its CCP (Customs Compliance Portal) bolt-on, are filing faster and encountering fewer roadblocks.

Following the Supreme Court’s ruling that the IEEPA tariffs were unlawful, CBP had to refund approximately 330,000 importers who had paid an estimated $166 billion in IEEPA duties across more than 53 million entries. But there was no way to process those refunds individually. To hasten refund operations, CBP built the CAPE (Consolidated Administration and Processing of Entries) tool within the ACE portal. Phase 1 launched on April 20.

An importer of record (IOR) or authorized customs broker logs in to the ACE portal, navigates to the CAPE tab, and uploads a CSV file containing entry numbers for a refund. Each declaration can contain up to 9,999 entries and can be submitted multiple times.

ACE has two rounds of validation. The first round checks if the submitter is an IOR or an authorized broker and whether the format is correct. But the second checks that each entry has an IEEPA Chapter 99 HTS code and that there are no duplicates. The system deletes and recalculates IEEPA duties for entries that pass both rounds. And then come the refunds, which include the statutory interest and are issued via ACH within 60 to 90 days. Notably, CAPE declarations cannot be edited once submitted. Rejected entries must be corrected and resubmitted on a new declaration.

Phase 1 covers unliquidated entries and entries liquidated within 80 days of submission. With that rolling window, timing is very important. It does not include reconciliation entries, entries with pending protests, warehouse entries, and drawback-related cases. Although future phases are expected, they are not confirmed. Importers with protest-pending entries face a tough choice: withdraw the protest to qualify for Phase 1 or wait for Phase 2, which has no timeline.

CBP has confirmed that roughly 82% of IEEPA duty payments (about $127 billion) are eligible in CAPE’s initial deployment. Interest is compounded daily. But the government has until early June to appeal the order to refund the tax, and a successful appeal could delay the entire process.

The first week of CAPE was rough. Importers reported problems with the portal being down, duplicate tax ID errors, and opaque rejection notices. Some 11.2 million entries passed file-level validation, of which about 19% were rejected during entry-specific checks. That is almost 1-in-5. CBP also estimates that $46 billion in refunds are tied up for importers without ACH refund enrollment.

Before you upload a declaration, you must have an ACE portal account with an active importer subaccount, ACH refund banking information on file, and a clean list of eligible entry numbers with liquidation status. Post-summary corrections cannot initiate IEEPA refund claims. Everything must go through CAPE.

The importers who filed on day one and cleared validation were those whose systems gave them an advantage through thorough preparation.

CAPE requires a central documentation repository, which Laufer’s CCP delivers, with entry summaries, HTS classifications, liquidation status, and tariff breakdowns with granular slicing by tariff type (232, 301, AD/CVD, and IEEPA). CCP users get that data from a single source, rather than having to compile entry numbers from scattered sources, which is how mistakes are made.

PeerPLUS provides end-to-end milestone visibility from the booking stage, with downloadable Excel exports that link back into the platform. That trail of structured data is valuable because the difference between a clean CAPE filing and a rejected one is whether your input data was structured before the portal went live.

Laufer’s PeerPLUS and CCP can help fill any gaps in your team’s customs data tracking highlighted by CAPE. Contact us today to get started.