U.S. Launches CAPE for More Than $160 Billion in IEEPA Duty Refunds from April 20, 2026

1. Introduction

As of April 20, 2026, U.S. Customs and Border Protection, or CBP, has officially launched Phase 1 of the Consolidated Administration and Processing of Entries, or CAPE, in the ACE Portal to process refunds of duties collected under the International Emergency Economic Powers Act, or IEEPA. Reuters reported that the total amount at issue is about $166 billion, making this one of the largest tariff refund programs ever administered by CBP.

The key operational change is that eligible claims can now be submitted in bulk, rather than handled one entry at a time. CBP states that valid IEEPA refunds will generally be issued within 60 to 90 days after CAPE acceptance, subject to eligibility and system processing.

2. What is CAPE?

CAPE stands for Consolidated Administration and Processing of Entries. It is a new ACE Portal functionality that allows importers and authorized customs brokers to submit IEEPA duty refund claims electronically through a consolidated process. CBP’s CAPE resources explain that a single declaration can include multiple entry numbers, which is intended to reduce manual entry-by-entry processing.

Reuters also reported that the system is designed to consolidate refunds into one electronic payment, with interest when applicable, rather than issuing refunds on an entry-by-entry basis.

3. Who is actually entitled to the refund?

This is the most important point to clarify.

Eligibility for an IEEPA duty refund is not determined by whether the company is American or Vietnamese. The refund right is tied to the party that is legally recognized on the U.S. import transaction, namely the Importer of Record, or IOR, or another party properly designated to receive the refund. CBP’s guidance consistently ties importer identity to the IOR record maintained in CBP systems, including Form 5106 processes.

In practical terms:

• If the U.S. buyer is the Importer of Record, the refund will typically belong to that U.S. importer, or to its properly designated refund recipient.
• If a Vietnamese company acts as the Importer of Record on the U.S. entry, has a valid importer identity on file with CBP, and has the required ACE and ACH refund setup, that Vietnamese company may be eligible to receive the refund.

A customs broker may be authorized to file the CAPE declaration if it filed the original entry, but that does not automatically make the broker the refund payee.

4. Which entries are covered in Phase 1?

CBP’s IEEPA refund guidance and CAPE trade materials show that Phase 1 is focused on recent and relatively straightforward entries. The key categories include:

• Unliquidated entries
• Entries liquidated within the last 80 days
• Certain entries in statuses such as suspended, extended, or under review, although actual refund timing may differ for those entries

For entries liquidated more than 80 days ago, CBP’s fast-track Phase 1 process may no longer be available. In those cases, importers should immediately evaluate the 180-day protest window. CBP states that a protest may be filed within 180 days of liquidation.

5. How does the filing process work?

CAPE claims are submitted through the ACE Portal using a CSV template. CBP trade materials state that one CAPE declaration may include up to 9,999 entries.

The filer must be either:

• The Importer of Record, or
• The customs broker that filed the original entry.

Once the system accepts a declaration, it assigns a Claim Number. The claim is not meant to be edited directly after submission, so importers should validate entry data carefully before filing. Reuters reported that some early users encountered upload issues on larger batches, which reinforces the need for careful file preparation.

6. How will the refund be paid?

CBP’s IEEPA refund guidance states that valid refunds will be issued through ACH, and importers should ensure they are properly enrolled to receive customs-related refunds electronically. If ACH refund information is not properly set up, payment can be delayed.

CBP also notes that any outstanding debt owed to CBP may be offset against the refund before disbursement.

7. How should importers interpret the refund timeline?

CBP states that valid IEEPA refunds will generally be issued within 60 to 90 days following acceptance of the CAPE declaration. For entries that have already liquidated and remain within the Phase 1 window, reliquidation may occur quickly. For many unliquidated entries, the system reference point is approximately 45 days to liquidation before refund issuance is triggered.

However, these are reference timelines, not hard guarantees. Reuters reported that while many claims are expected to move through automated validation, some more complex filings may be routed for manual review. That means an accepted status only confirms that the claim entered the system. It does not mean payment is imminent.

8. What should importers do now?

To protect refund rights and avoid processing delays, importers should take the following steps immediately:

• Confirm the Importer of Record on each affected entry
• Review whether each entry is unliquidated, liquidated within 80 days, or outside the Phase 1 window
• Decide whether the CAPE declaration will be filed by the IOR or the original customs broker
• Verify ACH refund enrollment in ACE
• Review any open protests and assess whether protest timing affects the filing strategy

For exporters selling into the U.S., this distinction matters. A Vietnamese company may ship the goods, but if the U.S. buyer is the Importer of Record, the refund right generally belongs to that U.S. importer, not to the foreign seller.

9. Why this matters

The CAPE rollout is not just a technical update. It is the operational mechanism for returning more than $160 billion in IEEPA duties collected by the U.S. government. Reuters reported that more than 56,000 importers had already completed key preparatory steps by early April, with approximately $127 billion tied to those participants.

For importers, the most important question is not simply when the money will arrive. The first question is who legally owns the refund claim. The second is whether the affected entries actually fit within Phase 1 eligibility parameters.

10. Frequently Asked Questions

1. Can a Vietnamese company receive an IEEPA duty refund?

Yes, but only if it is the Importer of Record on the U.S. entry, or if it has been properly designated as the refund recipient.

2. If the U.S. customer is the Importer of Record, who gets the refund?

In most cases, the refund belongs to the U.S. importer, or to its authorized refund payee.

3. Does Phase 1 apply to every entry?

No. Phase 1 mainly covers unliquidated entries and entries liquidated within the last 80 days, with some additional treatment for entries in special statuses.

4. Are refunds issued by paper check?

CBP’s current guidance for CAPE points importers to electronic refund enrollment, and valid refunds are expected to be disbursed through ACH.

5. Does “accepted” mean the refund is about to be paid?

No. “Accepted” means the declaration has entered the system. Additional review or processing may still occur before payment.

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