How is CAPE currently processing refund claims?
First, data accuracy is critical. One of the most frequently encountered system messages, “Unable to calculate duty,” highlights a broader issue: CAPE will not reconcile discrepancies between the refund submission and the original entry data. Even minor variances in HTS classification, entered value, quantity or duty calculation can prevent automated processing and result in the claim being routed for manual CBP review.
Second, CBP appears to be applying a form of queue segmentation. Submissions that align closely with original entry data are progressing more efficiently, while entries involving post-entry changes, liquidation status complications or data inconsistencies are more likely to be diverted into secondary review channels.
Third, there is no indication that CAPE will operate as a “file and forget” process. CBP has consistently signaled that IEEPA refund claims may be subject to review, documentation requests and potential post-refund audit activity.
As claims begin to move into active handling, these dynamics become more pronounced. Processing activity does not eliminate review risk and may increase the likelihood that discrepancies are identified as claims advance.
Why is pre-submission review critical for IEEPA refunds?
CAPE is not a passive system. It is the front-end intake for a CBP review and validation process.
Early indicators suggest CBP is distinguishing between:
- Submissions that are internally consistent and well supported
- Submissions with classification errors, valuation inconsistencies, country of origin issues or tariff stacking problems (e.g., Section 232, Section 301)
These issues do not just slow processing. They can trigger:
- Additional CBP review or inquiries
- Delayed liquidation or reliquidation
- Potential offsets or compliance exposure
This is why IEEPA refund audit and validation work prior to CAPE submission is essential.
What is the biggest risk for importers right now?
There is a strong pressure across the market to move quickly and get in line for refunds.
A fast submission that is incomplete or inconsistent is more likely to:
- Be flagged for CBP review
- Sit in extended processing queues
- Create downstream compliance issues
A slightly slower, well-audited submission is more likely to move cleanly through CAPE and into payment.
As processing activity begins to emerge, this risk becomes more pronounced. Movement through the system does not reduce exposure and may increase the likelihood of review.
How can importers track refunds through ACE?
Importers can now track refunds through ACE reporting.
Key reports include:
- REV-603 Trade Refund Report for tracking refund status and history
- REV-613 ACH Rejected Refunds Report identifying failed payments
- REV-615 report providing visibility into refunds issued, pending or applied
These reports reflect a more transparent and traceable refund process, but access alone is not sufficient. Data must be interpreted and reconciled back to entries and filings.
What should importers do before submitting through CAPE?
Importers should take a disciplined approach to IEEPA refund filings:
- Ensure that all refund data precisely matches the original entry summary at the line level
- Confirm that IEEPA duty lines are correctly linked to underlying HTS classifications
- Review the liquidation status of entries prior to submission
- Maintain clear documentation supporting duty paid and calculation methodology
Timing, accuracy and process discipline remain critical. Claims that are properly prepared and submitted are beginning to show signs of movement, while those not yet filed remain exposed.
The opportunity to recover IEEPA tariffs and overpaid duties is significant. Outcomes are driven by preparation.
What challenges exist for nonresident importers?
As CAPE submissions begin moving into refund processing, an additional issue is coming into focus: payment execution.
CBP is issuing refunds via ACH payments tied to ACE accounts with valid U.S. banking information. While this works efficiently for U.S.-based importers, it can create challenges for nonresident importers (NRIs) that do not have U.S. banking infrastructure in place.
In these cases, even approved claims may face delays at the point of payment.
For organizations operating as NRIs, confirming ACH setup and ACE configuration should be addressed alongside filing strategy.
For a deeper look at this issue, see our separate insight on nonresident importers and CAPE refund payment barriers.
What is Baker Tilly’s approach to CAPE and IEEPA refunds?
Given current conditions, our approach remains consistent:
- Full audit of entries prior to CAPE submission
- Validation of HTS classification, customs valuation and country of origin
- Identification of Section 232, Section 301 and other tariff exposure risks
- Development of a defensible filing strategy aligned with CBP expectations
For clients who have already submitted, now is the time to:
- Review what was filed
- Identify inconsistencies
- Prepare for potential CBP follow-up
For those preparing to file, this is the window to ensure your IEEPA refund claim is accurate, complete and defensible.
What should importers watch next?
Additional clarity from CBP is expected in the coming weeks as:
- CAPE processing stabilizes
- Review patterns become more visible
- Acceptance and rejection trends emerge
We are actively tracking:
- Submission-to-acceptance timelines
- CBP review outcomes
- Refund processing speed
This data will be critical for refining IEEPA refund strategies and recovery timelines.
Bottom line: What should importers take away from CAPE right now?
The portal is open, but this is not a mechanical process. It is a review-driven one. Organizations that get their data right on the front end will move faster, with fewer disruptions and greater certainty.
Early signals indicate that the system is beginning to move beyond intake and into active processing. This is a positive development, but it also suggests that claims are entering a phase where review activity is more likely.
Organizations should ensure that their data, documentation and positions can withstand the next stage of scrutiny.
If you are working through an IEEPA refund, evaluating a CAPE submission or want a second review before filing, we can help.
