Consolidated Administration and Processing of Entries (CAPE)

4/29/2026 Update

On April 28, 2026, Brandon Lord, Executive Director, Trade Programs Directorate of CBP issued an update on the CAPE system to the Court of International Trade (CIT). In his update, he advised the Court that CAPE is working as intended and was only unavailable to importers to submit declarations for an 18 minute period on its initial launch day, April 20. CBP saw a 70% increase in ACE login traffic during this time.

From Monday April 20, 2026, to Sunday April 26, 2026, CBP reports:

• 75,306 CAPE Declarations submitted
• 11,222,927 entries passed validations and were accepted for removal of IEEPA duties
• 2,124,394 entries failed validations
• 1,740,000 entries have been liquidated. Refunds are being issued

CBP did not give any specifics on any further CAPE phase developments beyond Phase I. CBP provided no timeline to when the Treasury Department will be issuing refunds on those 1.7m entries that have been liquidated though CAPE.

 

4/23/2026 Update

CAPE was officially launched within ACE at 8am eastern time on April 20, 2026. With as much attention as CAPE and the overall IEEPA refund process has been getting, many expected ACE login issues, long wait times or website crashes. There were some reports of small issues with ACE during the opening hours, including a 30 minute lockout but most users were reporting smooth operations on day one. CBP has reported 55,000 logins covering 4 million entries with a 98% successful login rate on the first day. CBP’s ACE help desk is now available 24 hours a day, starting Sundays at 5am to Saturday at 10pm ET.

On opening day, CBP also published a CSMS message adding a new ACE error condition to the Entry Summary Error dictionary. If attempting to file a Post Summary Correction for an entry for which is also on a CAPE declaration, an importer will receive error 864 “PSC NOT ALLOWED – REFUND REQUESTED” with an explanation “PSC is not allowed due to a CAPE Refund in process”. Importers should complete any post summary corrections on entries prior to including that entry on a CAPE declaration.

Importers are starting to see changes and updates to their entries though ACE reports to indicate CAPE is working through the process. Importers may see their IEEPA duties removed from entries through the ES-003 report but not yet showing up on the ES-022 (CAPE Entry Summary Report). This indicates the system is still working and processing entries.

Customs will not be issuing refunds by entry number. They will provide consolidated refunds which could include many entries, and, for some importers, could be for all entries. This could make it difficult to match refund amounts to individual entries for finance audits and reviews. Importers may need to work with finance departments to help reconcile their finances.

It’s important for importers to be aware that certain types of entries and scenarios are not eligible to be included on a CAPE declaration. Entries with Open or Suspended protests are not eligible for a CAPE declaration, however, an importer may voluntarily withdraw the protest to make the entry eligible for CAPE. This is an easy decision if a protest was solely to preserve the importers right to IEEPA refunds but becomes more difficult if the protested issues on the entry go beyond that of IEEPA duties, such as valuation, classification or other duty charges.

For most entries processed through CAPE, the entries will liquidate at the time of refund issuance. This is important to understand if other issues or changes are needed on the entry included in the CAPE declaration since the entry will be liquidated. An importer will be limited to a CBP Protest to make additional changes as a post summary correction is not available for liquidated entries.

It’s important to be aware that a CAPE declaration isn’t just a simple refund request. For CBP to issue a refund for any purpose, not just related to IEEPA, they can and will review the entry for any other errors or duties owed. CBP has allocated 45 days for them to review entries submitted via a CAPE declaration and CBP can use IEEPA refunds to offset any other duties that may be owed due to errors after the CBP review. It’s important for importers to understand their entries, know any potential issues with those entries and rectify those entries through a post summary correction prior to submitting to CAPE. Even after a refund is issued, CBP still has 2 years to review and importers could receive CF28s related to IEEPA after the fact.

Importer Actions
• Gain access to your ACE account.
• Work with CBP’s ACE Support for further assistance
• Know entries for which IEEPA duties were paid.
• Review the entry’s eligibility status for CAPE declaration.
• Is the entry flagged for reconciliation?
• Perform an audit or review of each entry for other possible issues including classification, valuation, duty stacking, etc.
• Was IEEPA over or under paid on the entry?
• What are the risks of filing CAPE sooner rather than later.

4/17/2026 Update

CBP has recently provided the trade community with additional resources to help navigate CAPE. The following resources are a great way to get to know the new process.

• CBP CAPE Website
• Trade User Information Notice (April 8, 2026)
• Quick Reference Guide (April 2026)
• IEEPA Duty Refund Fact Sheet

CBP further clarifies:

• They currently do not have any deadlines set for importers to file Phase I CAPE declarations by. This may change in the future and CBP will communicate that information
• Trade attorneys are not able to submit a CAPE declaration on behalf of clients. This ability is only limited to the Importer of Record or the designated Customs Broker who filed the original underlining entry. If the importer used multiple brokers, communication and coordination with each broker is important.
• If a non-resident importer does not have a US bank account, they are unable to sign up for the ACH refund process in ACE. A agent will need to be designated on Form 4811.
• Additional Phases of CAPE development beyond Phase I have not been announced yet.
• Interest will be paid in addition to the original IEEPA duty paid in the same way interest is calculated on all CBP refunds under 19 U.S.C 1505.
• For technical related questions, please reach out to the newly created CBP email address: IEEPARefunds@cbp.dhs.gov.

4/13/2026 Update

CBP published CSMS 68340863 on 4/13/2026 providing further guidance to the importing community regarding additional details surround CAPE

CAPE will launch at 8am eastern time on April 20, 2026. Importers and brokers will have access to the CAPE tab within ACE to begin submitting entry numbers for the IEEPA refund process. Only the IOR or broker who filed the entry with IEEPA duties present will be able to submit CAPE declarations.

CAPE Declaration

IORs or brokers will submit a .CSV file containing up to 9,999 entry numbers to CAPE. Additional declarations will need to be submitted for additional entries. CAPE will run an initial series of validations and accept or deny the declaration in its entirety. Reasons for denial can include:
• Incomplete entry numbers
• Submitter is not the IOR or the broker who originally filed the entry
• The .CSV file was corrupted

CAPE will provide a reason why it was denied. Importers will need to file a new CAPE declaration once the errors are corrected.

Once a declaration passes the initial validations, it will run a second round of validations. If specific entries are found in error, those entries will be removed, and the rest of the declaration will proceed forward.

Entries not accepted in the Phase 1 launch
• Entry summary flagged for Reconciliation
• Entry type 09 Reconciliation entry
• Entry summary associated with a Drawback entry
• Entry type 47 Drawback entry
• Entry type 08 USMCA Duty Deferral entry
• Entry summary with an Open or Suspended Protest
• Entry summary with “open” or “closed” liquidation status (i.e. Temporary Importation under Bond entry)
• AD/CVD entry summary in pending liquidation status
• In order to timely apply the liquidation instructions imposed by the Department of Commerce (DOC), an AD/CVD entry with a liquidation status of pending or for which DOC has issued liquidation instructions will not be accepted on a CAPE Declaration.
• Entry summary over 80 days past the liquidation date
• Goods value amount not allowed on IEEPA HTS line.
o The entered value of the imported product reported on the entry summary line should be reported on the Chapter 1-97 HTS classification, unless Chapter 98 reporting provisions require the entered value to be reported differently.

Mass Processing

Once the declaration is accepted, CAPE will begin removing individual IEEPA duty lines on the entry summary. A new version of that entry summary will then be created without the IEEPA duties, taxes and fees. Interest will also be calculated and added to the refund amount.

Review and Liquidation/Reliquidation

Unliquidated entries will then be set to liquidate in 45 days from the CAPE declaration acceptance date unless liquidation status is listed as suspended, extended, or “under review”.

Refunds

Refunds will be consolidated by IOR and liquidation date. CBP will review if other debts are owed by the importer prior to issuing a refund. Refunds will be issued via ACH. If an importer has not yet signed up for the ACH refund process via ACE, it is highly suggested to complete prior to refunds being issued. Generally, refunds on liquidation entries are expected to be released 60-90 days after the CAPE declaration acceptance.

Protests and Post Summary Corrections

If an importer filed a Protest on an entry solely for refunding IEEPA duties paid, the Protest will have to be withdrawn prior to that entry being added to a CAPE declaration. Post Summary Corrections will not be allowed for purpose of initiating an IEEPA duty refund.