Is the CBP Refund Claims Portal Open Yet?

Informational only — not legal advice.

CBP's CAPE (Consolidated Administration and Processing of Entries) claims workflow is confirmed for eligible Phase 1 IEEPA entries beginning April 20, 2026. Filing is done via CSV through ACE, submitted by the Importer of Record or the authorized customs broker that filed the entries. Refunds are expected 60-90 days after a CAPE Declaration is accepted. CBP estimates Phase 1 covers approximately 63% of IEEPA-duty entries - importers with finally liquidated entries face a deferred Phase 2 with no stated deadline.

What CBP has confirmed about Phase 1

On April 10, 2026, CBP published CSMS #68315804 announcing Phase 1 deployment for April 20, 2026. The key operational details:

• Filing mechanism: CAPE Declaration submitted as a CSV file through the ACE Portal
• Who can file: The IOR, or the authorized customs broker that filed the entries
• Entry limit per declaration: 9,999 entries (multiple declarations permitted)
• CBP processing: CBP's described workflow involves removing the IEEPA HTS code, recalculating duties, and reliquidating on a consolidated basis per IOR
• Refund routing: consolidated by IOR, paid via ACH to the IOR or a Form 4811 designee
• Refund timeline: 60–90 days after CAPE Declaration acceptance, absent compliance issues
• Monitoring reports: CBP identified ACE Reports ES-022, REV-603, REV-613, and REV-615 for tracking CAPE declarations and refunds
• Technical contact: IEEPARefunds@cbp.dhs.gov
• General contact: traderelations@cbp.dhs.gov

Source: CBP CSMS #68315804 — CAPE for IEEPA Refunds, April 20, 2026 Deployment

What Phase 1 covers — and what it does not

Entries eligible for Phase 1

• Unliquidated entries
• Entries liquidated within the preceding 80 days (to clear the 90-day reliquidation deadline under 19 U.S.C. §1501)
• Entries with "Suspended," "Extended," or "Under Review" liquidation status
• Warehouse withdrawal entries

CBP estimates Phase 1 covers approximately 63% of all entries on which IEEPA duties were paid. (CBP CSMS #68315804)

Entries excluded from Phase 1

CBP's Phase 1 does not cover:

• Finally liquidated entries — entries where both liquidation and the 180-day protest period have expired
• Entries flagged for reconciliation or Entry Type 09
• Entries with drawback claim designations
• Entries with open protests already filed
• Entries not filed in ACE or lacking liquidation status

The finally liquidated exclusion is significant. The CIT issued a March 27, 2026 amended order requiring CBP to reliquidate finally liquidated entries — which CBP and trade counsel have interpreted as not requiring a prior protest filing. CBP acknowledged the order but stated it cannot accommodate finally liquidated entries in Phase 1 and committed to developing Phase 2 capability — with no announced timeline.

Sources: CBP CSMS #68315804; Greenberg Traurig — CIT Expands IEEPA Tariff Refunds to Cover Entries with Final Liquidations (Mar. 27)

Court supervision: March 19 – April 1, 2026

The CIT maintained active oversight of the CAPE buildout through a series of orders after the March 12, 2026 declaration:

March 19, 2026 — CBP progress report

CBP filed its court-ordered progress report. Component percentages as of that filing:

March 20, 2026 — CIT: "Satisfactory progress"; scope expanded to Brazil and India

Judge Eaton found CBP "continues to make satisfactory progress toward timely completion" and issued an amended order explicitly extending refund coverage to include IEEPA duties on imports from Brazil and India.

March 27, 2026 — CIT: Finally liquidated entries must be refunded without protest

The most significant order since March 12. Judge Eaton amended the prior order to require CBP to reliquidate entries for which liquidation is already final — without requiring importers to have filed a timely protest. CBP responded it cannot implement this in Phase 1 and deferred it to a future phase.

March 31, 2026 — CBP progress report

April 1, 2026 — CIT: "On track for April 20"

Senior Judge Eaton issued a final supervision order finding CBP "on track to meet the April 20, 2026 deadline" for Phase 1. The order acknowledged the finally liquidated entry exclusion and directed CBP to address those categories in future phases.

Sources: Thompson Hine — CIT Endorses Phase 1 Ahead of April 20 Rollout; Greenberg Traurig — March 20 order; National Law Review — March 27 order; Forvis Mazars — CAPE progress update

Who files — and who receives the refund

CBP says the CAPE Claim Portal is the web-based entry point for importers and brokers to submit IEEPA refund requests. CBP released CAPE in the ACE Portal on April 20, 2026, and made the workflow available to eligible importer and broker accounts.

Filing access is not the same as claim ownership

A broker may be able to submit a CAPE Declaration, but the refund still routes to:

• the Importer of Record (IOR), or
• a party the IOR designated via CBP Form 4811

That means if you economically paid the tariff but are not the IOR on the entry, a portal submission does not automatically route the refund to you. The refund path turns on what the entry papers show and the IOR/payee setup.

Express shipments note: For shipments moved via FedEx, UPS, or DHL, the carrier's brokerage entity may be the IOR of record - not the recipient. If you received an express shipment and the carrier filed the entry on your behalf as IOR, you may not be able to file a CAPE Declaration directly. Check the entry papers to confirm who is listed as IOR before filing.

Source: CBP CSMS #68315804

How to monitor CAPE status after filing

CBP published a follow-up CSMS on May 4, 2026 identifying ACE Reports that importers and brokers can use to monitor CAPE declarations and refunds. It also said IEEPA refund ACH transactions will begin as early as May 12, 2026.

CBP also notes that Entry Summary reports can include CF 4811 Notify Party Name and CF 4811 Notify Party Number, which matters when the IOR has designated a broker or other party to receive refund payments. (CBP CSMS #68536553)

Why CAPE still does not remove the upstream work

CAPE is a submission and processing mechanism. It does not substitute for claim preparation. CBP's own workflow still includes review, liquidation/reliquidation, and refund routing — which is why the entry-level work still matters before anything is filed.

1) You still need the entry records

To build a CAPE Declaration CSV, you need:

• CBP Form 7501 entry summaries, or
• ACE entry summary exports

See: CBP Form 7501 overview and Form 7501 PDF

2) You still need to know who controls the claim

If you are not the IOR, CAPE will not fix that mismatch. Confirm what the entry papers show and which party has authority to act before filing.

For the broader protest framework, see:

• CBP — Protests
• 19 U.S.C. §1514

3) You still need to check liquidation status for each entry

Phase 1 eligibility turns on liquidation status. An entry liquidated more than 80 days ago falls outside Phase 1. Knowing your entry's status now lets you prioritize correctly — and flag entries that may be waiting for a Phase 2 that has no confirmed timeline.

4) You still need to separate tariff regimes

CBP ended collection of IEEPA duties effective February 24, 2026 at 12:00 a.m. ET, but a separate Section 122 surcharge began one minute later. The CIT invalidated Proclamation No. 11012 on May 7, 2026, with direct relief limited to importer plaintiffs. Those are different legal regimes and should not be mixed in CAPE calculations.

Sources:

• CBP CSMS #67834313 — Ending Collection of IEEPA Duties
• CBP CSMS #67844987 — Imposing Temporary Section 122 Duties
• CIT Slip Op. 26-47 — Section 122 consolidated cases (May 7, 2026)

5) Finally liquidated entries still need attention

If your entries are finally liquidated and outside Phase 1, the March 27 CIT order is favorable in principle — no protest required — but CBP has not committed to a Phase 2 timeline. Tracking these entries now matters if you want to act quickly when Phase 2 opens.

Why someone would still use RefundArrow even with CAPE live

A portal changes where a submission is eventually made. It does not remove the upstream work:

• Document retrieval first — most users still need help getting their 7501s / ACE exports to build the CSV
• IOR vs consignee diagnosis — portal access does not answer who actually controls the refund
• Liquidation status triage — Phase 1 vs Phase 2 eligibility turns on per-entry liquidation data
• Duty separation — IEEPA must be isolated from Section 122 / 232 / 301 and other nonrefundable duty types
• Finally liquidated entry tracking — 37% of entries are outside Phase 1; someone needs to monitor Phase 2 timing
• Broker-ready organization — a clean, complete CAPE Declaration CSV still requires organized entry records

In plain English: even with CAPE Phase 1 available, many importers still need help getting from "I think I paid these tariffs" to "here is a complete, accurate CSV ready for the ACE Portal."

What to do now

If you already have documents

If you do not have documents yet

Start with:

1. your customs broker or carrier brokerage
2. any prior customs packets or duty invoices
3. your AP records for shipment identifiers and broker references

Your immediate goals are:

• get the entry numbers
• get the 7501s or ACE exports
• confirm the Importer of Record
• record liquidation status/date for each affected entry — Phase 1 eligibility turns on this
• identify any finally liquidated entries that fall outside Phase 1

Frequently asked questions

Does CAPE mean refunds will be automatic?

No. CBP's workflow includes review and liquidation/reliquidation before a refund issues. Filing a CAPE Declaration starts the process; it does not guarantee a result without records, correct IOR routing, and duty isolation.

If I paid the tariff, can I file even if I am not the Importer of Record?

Do not assume that. Refund routing turns on the IOR and any Form 4811 designee. The broker may be able to submit, but the refund routes to the IOR's ACH account unless a Form 4811 designee is on file. Confirm what the entry papers show first.

Should I wait for CAPE to open before gathering my records?

No. The CAPE Declaration is submitted as a CSV - you need the entry data in hand before you can file. Importers who have their records organized can file promptly.

What if my entries are finally liquidated?

Phase 1 does not cover finally liquidated entries. The March 27 CIT order held that CBP must eventually reliquidate these entries without requiring a protest, but CBP has deferred this to a future phase with no announced timeline. Track these entries separately and monitor for Phase 2 guidance.

What is the 80-day vs. 90-day rule?

Phase 1 accepts entries liquidated within the preceding 80 days. This is consistent with the 90-day voluntary reliquidation window under 19 U.S.C. §1501 — CBP's 80-day cutoff leaves time to complete reliquidation within the statutory deadline.