The federal government has created a new process to issue refunds for unlawful IEEPA tariffs.

U.S. Customs and Border Protection (CBP) is rolling out a system called CAPE (Consolidated Administration and Processing of Entries) to return tariff payments to importers.

This is the primary administrative pathway for recovering IEEPA tariff payments—separate from litigation.

Why This Is Happening

These refunds are not voluntary.

They are the direct result of successful legal challenges establishing that the government cannot impose sweeping tariffs under emergency powers without clear congressional authorization.

As those cases move through the courts, CBP has been forced to begin building a mechanism to return unlawfully collected duties.

CAPE exists because the government collected money it may not have had the authority to take—and now must be prepared to give it back.

What You Need to Know

• Refunds include tariffs paid + interest
• Refunds are processed through the ACE Portal
• Payments are issued electronically (ACH only)
• Refunds may be grouped together, not issued entry-by-entry
• The system is being rolled out in phases, starting April 20, 2026

Right now, not all entries qualify. More will be included in future phases.

Phase 1 (Starting April 20, 2026)

Currently limited to:

• Certain unliquidated entries
• Certain entries within ~80 days of liquidation

If your entries fall outside this window, you are not excluded—you are likely waiting for the next phase.

TERRA Action Checklist

Step 1 — Confirm You Are Eligible

• You are the Importer of Record (or authorized broker)
• You paid IEEPA tariffs (Chapter 99 duties)
• Your entries fall within the current CAPE phase

Step 2 — Get Into ACE

• Confirm you have an ACE Secure Data Portal account
• Confirm you can access your entry data
• Coordinate with your broker if needed

If you do not have ACE access, start here. This is required.

Step 3 — Set Up Payment Information

• Enter ACH banking information in ACE

No ACH = No refund.

Step 4 — Identify Your Entries

• Pull all entries with IEEPA tariffs
• Gather:
  • Entry summary numbers (7501 data)
  • Supporting documentation (if applicable)

Step 5 — Prepare Your Filing

• Format your entries into the required CSV upload file
• Double-check for accuracy

Errors here will delay your refund.

Step 6 — Submit Your CAPE Declaration

• Log into ACE
• Upload your data through the CAPE module
• Review and submit

Step 7 — CBP Processes the Refund

Once accepted, CBP will:

• Remove IEEPA tariff charges
• Recalculate duties
• Liquidate or reliquidate entries
• Issue your refund (with interest)

Step 8 — Receive Your Refund

• Paid via ACH
• May be combined across multiple entries
• Estimated timeline: ~60–90 days after acceptance

What to Watch

• This is an evolving system—additional phases are coming
• Many importers will not be eligible yet
• Timing depends on:
  • Eligibility phase
  • Accuracy of your submission
  • CBP processing

Bottom line:
If you are eligible now, act.
If you are not, prepare your data so you are ready when your phase opens.

Additional Resources

For additional information about ACE Portal access and ACH refunds, visit the resources below:

• One Page Overview: ACH Refund Enrollment
• Frequently Asked Questions: ACE Portal and ACH Refunds FAQs
• Training Video: Applying for an ACE Portal Importer Account and Enrolling in ACH Refunds
• Training Guide: ACE Portal Importer Account Application
• Training Guide: ACH Refund Enrollment in the ACE Portal
• Rejected ACH Refund Information: Replacement Refund Instructions