Today, CBP's Executive Director of Trade Programs filed a declaration with the U.S. Court of International Trade providing a progress update on the agency's new IEEPA duty refund processing system called CAPE (Consolidated Administration and Processing of Entries). The system has four components and remains under development: the Claim Portal is 85% complete, Review and Liquidation/Reliquidation is 80% complete, the Refund component is 75% complete, and Mass Processing is 60% complete. CBP represents that development remains on schedule. While a date was not announced for the start up of the claims process, previous reports indicated a goal of late April.
Phase 1 of CAPE will cover roughly 63% of entries on which IEEPA duties were paid. Liquidation status is the single most important factor in determining whether your entries qualify for Phase 1 and when you will see a refund. Once CBP accepts a filing, the processing time is expected to take approximately 45 days to validate and process refunds on the relevant entries.
Phase 1 will cover:
- Unliquidated entries
- Entries liquidated within the prior 80 days (to allow reliquidation before the 90-day deadline for voluntary liquidation changes by CBP)
- Entries with a liquidation status of suspended, extended, or under review.
- Warehouse and warehouse withdrawal entries
Key types of entries not covered in Phase 1 include:
- Entries fully liquidated ( 90 days after liquidation date)
- Entries with open protests
- Entries designated on drawback claims
All refunds are now issued electronically as of February 6, 2026. It is essential to be enrolled in the ACH refund program in the ACE portal to obtain refunds.
Key action items:
- Enroll immediately for electronic refunds via CBP Form 4811 if you have not already done so
- Audit your entry portfolio now and sort entries by liquidation status to understand your Phase 1 eligibility and expected refund timeline
- If your exposure is concentrated in fully liquidated entries, plan for delays and watch for further updates
- Flag entries with open protests, drawback claims, or reconciliation issues for separate Phase 2 tracking
We will continue to monitor the updates from CIT and CBP as they become available. Should you need assistance analyzing your entries phase eligibility please reach out to hear how we can help.
