CBP Declares CAPE Refund System Under Active Development

In a declaration filed today in Atmus Filtration, Inc. v. United States (Court No. 26-01259), Brandon Lord, Executive Director of Trade Programs at U.S. Customs and Border Protection, has provided the most detailed public account yet of CBP's plans to process IEEPA tariff refunds through a new system called CAPE — the Consolidated Administration and Processing of Entries.

The declaration, filed in response to a March 6, 2026 Court Order from Senior Judge Richard K. Eaton, outlines a four-component system being built within the Automated Commercial Environment (ACE) to calculate and issue refunds of additional ad valorem duties imposed under IEEPA.

The Four Components of CAPE

Claim Portal (70% complete). A web-based entry point where importers and brokers submit IEEPA refund requests via ACE Portal accounts. Filers will upload CSV files listing the entry summaries for which they are requesting refunds. The system will run file-level validations (formatting, submitter authorization, file integrity) and entry-specific validations (confirming entry existence in ACE, verifying IEEPA HTS Chapter 99 numbers). CBP has finished the user interface and is currently developing the automated validation logic.

Mass Processing (40% complete). This component will automatically strip applicable IEEPA HTS numbers from validated entry summaries and recalculate duties as if the IEEPA duties had never been declared. The standard ACE duty calculation validations will then run. Development is focused on the automated entry summary update process.

Review and Liquidation/Reliquidation (80% complete). Entries from accepted CAPE Declarations will be set to liquidate or reliquidate on a specified schedule, with CBP retaining the ability to conduct manual review. This component will update underlying entry summaries with new duty totals and automatically calculate interest. Processing will occur Monday through Thursday each week. The liquidation/reliquidation function is complete and performance testing is about to begin.

Refund (60% complete). ACE will direct entries reaching their scheduled liquidation/reliquidation date to a CAPE-specific refund process within the ACE Collections module. Refunds will be consolidated by liquidation/reliquidation date and importer of record (or Form 4811 designee), then sent electronically to designated bank accounts. CAPE-specific refund processing is built and consolidation performance testing is underway.

Phased Rollout

CBP anticipates a phased deployment. The first phase will cover the majority of formal and informal entries on which IEEPA duties were paid, excluding unliquidated entries subject to antidumping or countervailing duties, entries with "Suspended," "Extended," or "Under Review" liquidation status, warehouse withdrawals, entries designated on drawback claims, and certain other entry types. Detailed guidance will be published as each phase is implemented.

CBP is also evaluating compliance with the Paperwork Reduction Act.

Read the Full Filing