IEEPA Refunds Are Open, Section 232 Changed, and the Government Just Doubled Down on Trade Enforcement
CAPE Goes Live — The IEEPA Refund Portal Is Open
On April 20, CBP launched Phase 1 of the Consolidated Administration and Processing of Entries tool inside the ACE Secure Data Portal. CAPE is now the exclusive mechanism for submitting IEEPA refund claims for any entry that includes at least one IEEPA Harmonized Tariff Schedule Chapter 99 code. Traditional post-summary corrections and protest procedures can no longer be used for IEEPA refunds covered under Phase 1.
This is the moment importers have been waiting for since the Supreme Court struck down IEEPA tariffs in February. But refunds are not automatic. You have to file. And how you file will determine how quickly — and whether — you get paid.
What Phase 1 covers:
Unliquidated entries
Entries liquidated within the preceding 80 days (liquidated after January 30, 2026)
CBP estimates Phase 1 covers approximately 63% of affected entries across the 330,000 importers who paid IEEPA duties. The remaining entries — those under reconciliation, on drawback claims, with open protests, subject to AD/CVD, or finally liquidated — are not covered yet. CBP has confirmed it is developing subsequent phases but has not given a timeline for any of them. CBP is expected to file another update with the Court of International Trade on April 28 covering Phase 1 progress. If your exposure sits in those categories, watch that filing closely.
Before You File: Three Things That Must Be Done First
These are not optional steps. Skip any one of them and your refund does not move.
1. ACE Portal account with an Importer sub-account. The CAPE tab only appears in Importer, Organizational Broker, and Filer sub-accounts. If you do not have an Importer sub-account set up, you cannot enroll in ACH refunds and you cannot receive payment. Apply at the ACE Secure Data Portal if you do not have one.
2. ACH bank account enrolled in ACE. All IEEPA refunds are paid electronically via ACH. No paper checks. This is not automatic — it is a manual setup step inside the Importer sub-account. If your ACH information is missing or outdated, CBP will hold your refund indefinitely. It will not bounce back to you. It will just sit there until you fix it. As of late March, nearly one in four importers had not completed ACH enrollment. Do this now, before you file.
3. Your entry numbers compiled and validated. Pull every entry number on which IEEPA duties were paid. These can be queried through ACE. Cross-reference against Phase 1 eligibility criteria — unliquidated or liquidated within the last 80 days. Know which entries are in and which are out before you touch the CSV template.
How to File a CAPE Declaration
Once your account is set up and your list is ready:
Go to the CAPE tab in your ACE Portal account
Select the Upload button
Download the CAPE Upload Template — this is a CSV file
Enter your eligible entry numbers in the first column. Entry numbers only. CBP requires nothing else in the file
Save in CSV format and upload through the CAPE tab
Upon validation and acceptance, you will receive a CAPE claim number
Each CAPE Declaration has a limit of 9,999 entries. You can file multiple declarations. A customs broker can include entries filed on behalf of multiple IORs on a single declaration — there is no requirement that a broker's CAPE Declaration cover only one importer.
Once your declaration is accepted, ACE removes the IEEPA Chapter 99 HTS provisions from the affected entry summary lines and recalculates the duty owed without IEEPA tariffs. CBP then reviews and liquidates or reliquidates the entries. Refunds are consolidated by IOR and liquidation date and issued via ACH to the IOR or the party the IOR has designated through CBP Form 4811.
A few hard rules to know before you submit:
Once a CAPE Declaration is accepted, it cannot be amended. If you find additional eligible entries after the fact, you file a new declaration. Each entry can only appear on one accepted declaration — if you include an entry that was already submitted, it will be rejected.
One important nuance on PSCs: entries that have been accepted and attached to a CAPE claim are not eligible for post-summary corrections. However, if an entry is rejected from your CAPE submission, you can correct it via PSC and then include it on a subsequent CAPE declaration. And if a PSC has already been filed on an entry before you submit to CAPE, that entry can still be accepted. The sequencing matters.
Attorneys cannot file CAPE Declarations. Only the IOR or the licensed customs broker who originally filed the entries is eligible to submit. Not your current broker if they did not file the original entry. The broker who actually touched that entry at the time of filing is the only one who can submit the CAPE Declaration for it. If your imports spanned multiple brokers during the IEEPA period, your refunds are coming in waves — one for each broker, processed in the order they submit. The broker who moves first gets paid first. The broker who drags their feet delays your money.
The Error Table You Need Before You Submit
CBP validates both the declaration itself and every individual entry on it before issuing a CAPE claim number. Any entry that fails validation is removed from the declaration. The valid entries continue processing. You can see which entries were accepted and which were rejected and why.
If your declaration fails at the file level rather than the entry level, the entire submission is returned. Clean your data before you upload.
Here are the rejection errors and what they mean:
NO IEEPA HTS ON ENTRY — the entry must have at least one IEEPA Chapter 99 HTS code. If it does not, there is nothing to refund and the entry does not belong in your CSV
ENTRY SUMMARY IS IN FINAL LIQUIDATION STATUS — liquidated more than 80 days ago, not eligible for Phase 1. These entries are in a later phase with no confirmed timeline
PROTEST ON ENTRY — entry cannot have an open or suspended protest, or a denied protest with the AFR box checked. Resolve the protest before including the entry
ENTRY SUMMARY FLAGGED FOR RECON — reconciliation entries are excluded from Phase 1
ENTRY ON DRAWBACK — drawback entries are excluded from Phase 1
ENTRY TYPE NOT ALLOWED — TIB (type 23), Duty Deferral (08), Reconciliation (09), and Drawback (047) entry types are not permitted
STATEMENT PROCESSING NOT COMPLETE — the entry is on a statement authorized for payment but payment has not yet processed. Wait until it clears
ENTRY SUMMARY IS IN TRADE CONTROL — control status must be with CBP, not flagged otherwise
ENTRY SUMMARY UNDER REVIEW — entry is in adjusted status and cannot be included
UNABLE TO CALCULATE DUTY — one or more lines on the entry fail duty calculation validation. This likely means there is a data problem on the entry itself
GOODS VALUE AMOUNT NOT ALLOWED ON IEEPA HTS LINE — the IEEPA HTS code cannot carry a goods value amount greater than zero
ENTRY SUMMARY IS SUBJECT TO COURT INJUNCTION — entry is flagged for injunction and cannot be processed
ENTRY SUMMARY PENDING LIQUIDATION OR NOT LIQUIDATED AND HAS SUSPENSION RECORD — entry has a liquidation status of pending or not liquidated and also has a suspension record
Suspended, extended, or under-review entries can still be included in your CAPE Declaration. They will maintain their liquidation status and the refund, if validated, will be issued when the entry eventually liquidates.
"Unless a Compliance Concern Requires Further CBP Review."
CBP's guidance states that refunds will generally be issued within 60 to 90 days "unless a compliance concern requires further CBP review."
Here is what that means in practice. An audit of entries filed by outside brokers found an average error rate of 20%. One in five entries. That means some importers are about to walk into CAPE and leave 20% of their total refund on the table — while simultaneously flagging those entries for CBP scrutiny at exactly the moment the agency is paying the closest attention it has paid to entry data in years.
Think about what CAPE is asking CBP to do. Process refunds across 53 million entries filed during one of the most chaotic tariff environments in modern U.S. trade history. Misclassifications, valuation errors, incorrect country of origin declarations — these did not disappear when the IEEPA tariffs were struck down. They are sitting on your entries right now. And when you submit a CAPE Declaration, you are putting those entries in front of CBP for review.
A compliance concern does not just delay your refund. It puts the entire entry under a microscope. CBP is not going to isolate its review to the IEEPA duty line. If there is a problem anywhere on the entry, it is on the table.
There is also the netting question. CBP nets all over- and under-payments across the entire entry at liquidation before issuing a refund. If you underpaid duties elsewhere on an entry — wrong HTS code, understated value, incorrect rate — that underpayment offsets your IEEPA refund. You may get less than you expect, or nothing at all on that entry. Outstanding debts to CBP get applied first, before any refund balance is released.
None of this is a reason to avoid filing. The money is yours and you should go get it. But it is a very good reason to audit your entries before you put them in front of CBP. The importers who know what is in their entries before they submit are the ones who will get paid quickly and cleanly. The ones who don't may find that CAPE surfaces problems they did not know they had — at the worst possible time.
Identify all errors before you submit. Correct unliquidated entries via PSC first if needed, then include them on your CAPE Declaration. Do not hand CBP a reason to slow down your refund or open a broader review.
Tracking Your Refund After Filing
CBP has three ACE reports you should be running:
REV-603 Trade Refund Report — confirms successful refunds issued. Run this to verify payment.
REV-615 Trade CAPE Detail Refund Report — new as of April 20. Provides both consolidated CAPE refund information and entry-level detail. This is your primary tool for monitoring CAPE-specific activity.
REV-613 ACH Rejected Refunds Report — flags refunds that could not be issued because the recipient is not enrolled in ACH. If you see entries here, your banking information setup is incomplete.
Watch the Refund Secondary Status column in REV-603 and REV-615. If it shows "Funds Diverted," CBP has applied your refund against an outstanding debt before releasing the balance. Diversion happens after liquidation but before payment is issued.
For entry-level liquidation detail, run the ES-701 Courtesy Notice of Liquidation Report or the ES-702 Official Notice of Extension, Suspension and Liquidation Report. These will show the liquidated amount including the bill or refund and corresponding interest on change liquidations.
Questions: Technical questions go to IEEPARefunds@cbp.dhs.gov. General inquiries go to traderelations@cbp.dhs.gov.
What's Coming in Later Phases
CBP has confirmed it is evaluating the following for subsequent CAPE phases, with no timeline given for any of them:
Reconciliation entries and Entry Type 09
Entries designated on a drawback claim
Entries covered by an open protest
Entries not filed in ACE or without a liquidation status in ACE
AD/CVD entries with Department of Commerce liquidation instructions pending under 19 U.S.C. § 1504(d)
Finally liquidated entries
Reductions to Section 232 Tariffs on Steel and Aluminum Now Available for Canadian and Mexican Producers
The Department of Commerce published procedures this week for Canadian and Mexican steel and aluminum producers to apply for Section 232 tariff reductions. The program stems from a October 2025 proclamation that imposed Section 232 tariffs on medium and heavy duty vehicles and parts, which also authorized DOC to reduce steel and aluminum tariffs by up to 50% for qualifying producers.
To be eligible, producers must operate facilities in Canada or Mexico, supply U.S. automobile or MHDV manufacturers directly or through incorporation into parts, and commit to expanding primary steel or aluminum production capacity in the United States. Only new capacity commitments qualify. Existing production does not count. The steel or aluminum must qualify for preferential treatment under USMCA and must be melted and poured or smelted and cast in Canada or Mexico.
Tariff reductions are capped at quantities equal to the projected annual new U.S. production capacity and apply for a fixed period determined by DOC. Once DOC reviews a complete submission, it notifies CBP of the start date and quarterly import quantities eligible for the reduced rate. Quarterly reporting on shipments, volumes, and values is required. Miss your commitments and your entries get reliquidated at the full rate.
Eligible producers can begin submitting documentation now.
The FY2027 Budget Makes Clear That Trade Enforcement Is Not Slowing Down
The White House released its fiscal year 2027 budget proposal on April 3 and it is worth paying attention to if you are in trade compliance.
The proposal requests a 45% funding increase for USTR — enough to add roughly 70 staff positions to an agency that currently has just over 200 employees. The Bureau of Industry and Security at the Department of Commerce would see its budget nearly double, adding more than $200 million to the agency responsible for export controls and product-based Section 232 tariffs. The International Trade Administration gets more money for antidumping and countervailing duty enforcement, even as its trade promotion budget gets cut. And CBP gets an additional $136 million specifically to modernize ACE — the same system now being used to process IEEPA refunds.
Read that last one carefully. The administration is investing in the infrastructure that collects tariffs, processes entries, and issues refunds. More staff, more enforcement capacity, more scrutiny across the board.
This is not a budget that treats trade compliance as a background function. It is a budget that treats trade as a weapon and enforcement as a priority. For importers and exporters, that means classification errors, valuation discrepancies, and origin misstatements are going to get more attention, not less.
For trade compliance professionals, this is the environment you are operating in for the foreseeable future. The role is not shrinking. If anything, the past two years have made clear that trade compliance sits at the center of business strategy in a way it simply did not before. Companies that once treated it as a back office function are now staffing up, paying attention, and asking hard questions about whether their teams have what they need to keep up.
The challenge is that the regulatory environment is moving faster than any team can manually track. Section 232 has changed multiple times. IEEPA got struck down. Section 301 investigations just expanded to sixteen economies. Section 122 is in court. Section 338 is suddenly in the conversation. Every one of those changes hits entries, classifications, duty rates, and refund eligibility in real time.
The compliance professionals who will stay ahead of this are the ones whose teams are not spending their days manually pulling CSMS messages, cross-referencing Federal Register notices, and updating spreadsheets. That work needs to be automated so the people who actually understand trade can focus on the decisions that require judgment. The volatility is not going away. The teams that build the right infrastructure around their compliance function now are the ones that will not be scrambling when the next change lands.
How Importal Solves This
Importal is the first AI powered licensed US customs brokerage. Our platform tracks every regulatory change in real time. When tariffs change, we catch them and apply updates to entries automatically.
The difference is that our licensed brokers have the right compliance data at their fingertips when they file your entries. When Section 232 rates change, when Chapter 99 codes shift, when new exclusions take effect, our system flags it before the entry gets filed. Not after CBP liquidates it wrong.
Traditional brokers are manually tracking CSMS messages, Federal Register notices, and executive orders. They are updating spreadsheets and hoping they caught everything. Our platform does that work in real time and surfaces it directly to our licensed brokers during entry filing.
