CBP Launches CAPE Portal: How the Automated IEEPA Tariff Refund System Will Process $175 Billion in Duty Recovery

The Supreme Court's February 2026 ruling striking down IEEPA tariffs sent shockwaves through global trade — but for over 330,000 importers who collectively paid approximately $166 billion in duties across 53 million entry summaries, the real question was never whether they'd get refunds. It was how.

Now we have the answer: CAPE — the Consolidated Administration and Processing of Entries — a brand-new automated refund processing system being built directly into CBP's Automated Commercial Environment (ACE) portal.

The Scale of the Problem: Why Manual Refunds Were Never an Option

The Penn Wharton Budget Model projects up to $175 billion in total refunds once all IEEPA tariffs are reversed. With 53 million affected entry summaries spread across hundreds of thousands of importers, processing refunds manually — the way CBP has historically handled individual protest-based duty recovery — would have taken years, possibly a decade or more.

That's why CBP filed a declaration with the U.S. Court of International Trade (CIT) on March 12, 2026, outlining CAPE as a purpose-built, automated claims infrastructure designed to handle refunds at a scale the agency has never attempted before.

Judge Richard Eaton described the process as satisfactory and continued the suspension of his order requiring immediate liquidation — buying CBP time to build the system properly.

How CAPE Works: Four Components From Claim to Cash

CAPE isn't a single tool. It's a four-stage automated pipeline, with each component handing off to the next without manual intervention. Understanding the flow is critical for importers preparing their claims.

Component 1: The CAPE Claim Portal

A new dedicated tab will appear in both importer and broker ACE Portal accounts. Filers upload a CSV file listing all entry summaries for which IEEPA refunds are being claimed. The portal then runs two sequential rounds of automated validation:

• File Validations — The first pass checks formatting, field completeness, filer identity, and file integrity. Any file failing this check is rejected entirely with specific error codes for correction.
• Entry Validations — Individual entries are checked against ACE records. Each entry must exist in ACE and contain at least one IEEPA HTS Chapter 99 number. Entries failing this check are removed individually; valid entries advance.

As of March 11, 2026, CBP reported the Claim Portal is approximately 70% complete.

Component 2: Mass Processing

Once a submission clears the Claim Portal, CAPE's Mass Processing engine takes over automatically. It performs two actions on every validated entry summary:

1. Removes all applicable IEEPA HTS Chapter 99 numbers from the entry
2. Recalculates duties as if IEEPA charges had never been assessed

The recalculation runs through ACE's standard duty calculation validations, ensuring revised figures comply with all existing system rules. Upon passing, CAPE formally accepts the declaration for each entry, locking in recalculated amounts.

Component 3: Review and Liquidation/Reliquidation

After formal acceptance, entries enter the review phase. CAPE automatically schedules each entry to liquidate or reliquidate within a set number of days, creating a window for CBP officers to conduct manual review if warranted.

This phase also automatically calculates any applicable interest owed to the importer and updates each entry summary with corrected final duty totals. Liquidations and reliquidations process Monday through Thursday each week — entries scheduled for weekends or federal holidays roll to the next available day.

As of March 11, this component is approximately 40% complete — the least mature piece of the pipeline.

Component 4: Electronic Refund Disbursement

When entries reach their scheduled liquidation date, ACE routes them through a CAPE-specific refund workflow. Refunds are consolidated by liquidation date and importer of record — or by a designated third party named on CBP Form 4811 — and transmitted electronically to bank accounts on file.

What CAPE Can't Process Yet

Not every entry will sail through CAPE on day one. The system initially cannot handle:

• Unliquidated entries subject to trade remedies (antidumping/countervailing duty) proceedings
• Entries where liquidation is suspended, extended, or under review
• Entries covering goods withdrawn from bonded warehouses or foreign trade zones
• Entries subject to drawback claims

CBP has stated it will update CAPE to process these more complex scenarios over time, but importers with entries in these categories should expect delays and should consult with their customs brokers or trade counsel to understand the timeline.

The March 19 Deadline: What's Coming Next

Judge Eaton has ordered CBP to file an updated progress report by March 19, 2026, just two days from now. This report will reveal:

• Updated completion percentages for all four CAPE components
• A more definitive timeline for when importers can begin filing claims
• Any technical or legal obstacles that have emerged during development
• How CBP plans to handle the complex entry categories excluded from initial processing

Importers should monitor this deadline closely. The March 19 report will likely determine the realistic pace at which refund funds begin flowing back to the private sector.

How Shippers Should Prepare Right Now

Don't wait for CAPE to go live. The importers who recover their money fastest will be the ones who've done the groundwork:

1. Audit your entry data — Pull every entry summary from your ACE account that includes HTS Chapter 99 IEEPA classifications. Verify completeness and accuracy now, before the portal opens.

2. Compile your CSV files — CAPE requires CSV-formatted entry lists. Start building these files with your customs broker so you can submit within days of the portal going live, not weeks.

3. Verify your banking information — Refunds will be disbursed electronically to the bank account on file. Confirm your ACE payment information is current and correct.

4. Identify complex entries — Flag any entries involving trade remedies, drawback claims, bonded warehouses, or FTZ withdrawals. These will require separate handling and potentially different timelines.

5. Coordinate with your broker — If you use a customs broker, confirm they're prepared to file on your behalf through the CAPE portal. Early coordination prevents bottlenecks.

How CXTMS Helps Automate Refund Preparation

For shippers managing hundreds or thousands of affected entries, manually compiling CSV files and auditing HTS classifications is a massive operational burden. CXTMS platforms can automate the heavy lifting — extracting entry data from your trade records, validating HTS codes against IEEPA classifications, and generating submission-ready CSV files that meet CAPE's formatting requirements.

When $175 billion is on the table and the filing window opens, speed and accuracy determine who gets paid first.

Ready to automate your IEEPA refund preparation? Request a CXTMS demo and get your entry data organized before CAPE goes live.