Article | Executive briefing

IEEPA refunds: Latest CBP guidance for importers

CBP expands CAPE Phase 2 for qualifying reconciliation entries.

June 25, 2026 · Authored by Pete Mento, Tosca Derrick and Danae Helgeson

U.S. Customs and Border Protection (CBP) continues to expand the process for IEEPA refunds, providing new guidance for importers seeking refunds of tariffs imposed under the International Emergency Economic Powers Act (IEEPA). This page provides the latest updates, background and practical guidance to help Importers of Record (IOR) understand evolving CBP requirements, evaluate refund opportunities and prepare for the IEEPA refund process.

On this page:

Latest update
Background: IEEPA refunds
What importers should do now
Timeline of key IEEPA refund developments
How to start your IEEPA refund claim

Latest update

On June 23, 2026, CBP published additional guidance on CAPE Phase 2 functionality, which is scheduled to launch June 29. The latest enhancement allows Consolidated Administration and Processing of Entries (CAPE) declarations for underlying entry summaries (entry types 01, 02, and 06) associated with reconciliation entries (entry type 09), expanding refund opportunities for eligible importers.

Reconciliation allows importers to update information that could not be determined at the time of entry, including customs value, HTSUS 9802 claims, tariff classification, and free trade agreement (FTA) eligibility. As with CAPE Phase 1, declarations will only be accepted for eligible entries that remain unliquidated or are within 80 days of liquidation.

Importers should pay close attention to the timing of reconciliation filings. Once a reconciliation entry has been filed through the normal process, the associated underlying entries are no longer eligible for CAPE Phase 2 processing. Evaluating liquidation dates, protest deadlines, and reconciliation timelines before filing can help preserve refund eligibility and maximize available recovery opportunities.

CBP also updated its IEEPA Refunds Frequently Asked Questions webpage [1] with additional guidance for the trade community and continues developing CAPE functionality for more complex refund scenarios beyond standard entry types. At the same time, the U.S. Court of International Trade continues to oversee implementation of the refund process. Judge Richard Eaton scheduled another status conference for June 25, 2026, and directed the government to submit its next CAPE progress report by July 1, 2026.

Background on IEEPA refunds

On Feb. 20, 2026, the U.S. Supreme Court ruled that the use of IEEPA tariffs to impose certain tariffs was unlawful. The affected tariffs had been imposed beginning Feb. 4, 2025, under multiple presidential executive orders. Following the decision, the U.S. Court of International Trade (CIT) directed CBP to establish procedures for processing IEEPA refunds owed to eligible importers.

CBP launched Phase 1 of the CAPE tool within the Automated Commercial Environment (ACE) Secure Data Portal on April 20, 2026, allowing eligible importers and authorized customs brokers to begin submitting CAPE declarations for qualifying IEEPA duty refunds. Rather than processing refunds on an entry-by-entry basis, CAPE is designed to consolidate refund processing, including applicable interest. Phase 1 currently applies to certain unliquidated entries and certain entries within 80 days of liquidation, while Phase 2 expands eligibility to include qualifying reconciliation entries.

What importers should do now

As CAPE functionality continues to expand, importers should review their entry population to identify eligible refund opportunities before key filing deadlines expire. Coordinating refund claims with reconciliation activity is increasingly important, as filing reconciliation before submitting a CAPE declaration could eliminate eligibility for certain underlying entries. Importers should also identify upcoming liquidation and protest deadlines and develop a filing strategy that preserves available refund rights while minimizing operational disruption.

Importers planning to pursue IEEPA refunds should also ensure they have access to the ACE Secure Data Portal. Establishing an ACE account can take up to six weeks, and additional time may be required to configure electronic refund capabilities. This preparation is especially important because CBP's Interim Final Rule (IFR) on Electronic Refunds (91 FR 21) requires all refunds to be issued electronically through ACE. Without an active ACE account and electronic refund setup, importers may experience delays in receiving approved refunds. CBP provides instructions for establishing an ACE Secure Data Portal account on its website [2].

Baker Tilly continues to monitor CBP guidance, CAPE implementation, and court proceedings as the IEEPA refund process evolves. As additional refund functionality becomes available, importers should continue evaluating their filing strategies to preserve eligibility and maximize potential refund opportunities.

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Timeline of key IEEPA refund developments

Month	Date	Event or milestone	Key outcomes and notes
February 2025	February 4, 2025	IEEPA duties became applicable to covered imports entered for consumption on or after this date.	For customs purposes, applicability is based on the entry date or warehouse withdrawal date, not ship or arrival date. Applicable rates varied by country of origin and Executive Order in effect at entry.
February 2026	February 20, 2026	U.S. Supreme Court held that use of IEEPA to impose certain tariffs was unlawful.	Following the decision, the CIT directed CBP to establish refund procedures. Importers became legally entitled to pursue refunds once CBP procedures were published.
March 2026	March 2, 2026	Federal Circuit denied DOJ request for delay and returned case to the CIT.	CIT regained authority to define IEEPA refund mechanics.
	March 4, 2026	Judge Richard Eaton ordered CBP to process unliquidated entries without IEEPA tariffs and reliquidate non-final liquidated entries.	CBP also ordered to explain refund and reliquidation procedures.
	March 6, 2026	CBP Executive Director Brandon Lord filed response outlining operational challenges with immediate refunds.	CBP estimated manual processing would require 4.4+ million labor hours for 53+ million entries. Proposed automated ACE-based refund process with tentative launch target of April 20, 2026. CIT paused immediate refund requirement.
	March 12, 2026	CBP formally introduced the CAPE (Consolidated Administration and Processing of Entries) system within ACE.	CAPE designed to automate refund requests, recalculations, liquidation/reliquidation, and refunds. Four components introduced: Claim portal, Mass processing, Review & liquidation/reliquidation, and Refund processing. Components estimated 40% - 80% complete.
	March 19, 2026	CBP provided CAPE development progress update.	Overall completion increased from 63% to 65%. Claim portal: 73%, Mass processing: 45%, Refund processing: 63%, Review & liquidation/re-Liquidation: 80%.
	March 20, 2026	CIT confirmed all IEEPA tariffs, including Brazil and India tariffs, are eligible for refunds.	CBP ordered to provide additional CAPE progress report by March 31, 2026.
	March 27, 2026	CIT expanded on their March 4th order to include finally liquidated entries.	CBP ordered to broaden IEEPA refund scope to those entries that have completed both the 314-day liquidation cycle and the 180-day protest period.
	March 31, 2026	CBP reported CAPE Phase 1 approximately 75% complete and outlined Phase 1 scope and exclusions.	Scope included unliquidated entries and entries within voluntary reliquidation window. Expanded functionality added warehouse and suspended entries. Exclusions included finally liquidated entries, drawback, protest, AD/CVD, and non-ACE entries.
April 2026	April 10, 2026	CBP issued CSMS #68315804 confirming April 20 launch of CAPE Phase 1.	Confirmed ACE portal and ACH enrollment requirements. Refunds to be consolidated rather than entry-by-entry.
	April 13, 2026	CBP issued CSMS #68340863 with operational guidance for CAPE deployment.	Guidance detailed CSV bulk filing process, automated validation, refund processing timelines, ACH refunds, and operational restrictions for protests, drawbacks, PSC filings, and AD/CVD entries.
	April 14, 2026	CBP reported CAPE Phase 1 reached approximately 90% completion.	Claim portal: 95%, Mass processing: 85%, Review & liquidation/reliquidation: 90%, Refund processing: 90%. Final testing underway. Approximately 82% of IEEPA refunds (~$127B) expected to process via ACH automation.
	April 20, 2026	CBP issued CSMS #68396594 announcing CAPE Phase 1 is live in ACE.	Importers and authorized customs brokers may now file CAPE declarations through ACE portal accounts. CAPE consolidates IEEPA duty refunds, including interest, rather than processing refunds entry-by-entry. Phase 1 is limited to certain unliquidated entries and certain entries within 80 days of liquidation. Supporting resources released by CBP include the CAPE information notice [3], ACE portal: CAPE declarations quick reference guide [4], and the IEEPA duty refunds page [1].
	April 28, 2026	CBP provided update to the CIT on CAPE processing status.	Approximately 11 million entries were accepted by CAPE and passed entry-specific validations. Of those, about 1.74 million entries have been liquidated and entered the refund process. While the system is generally functioning as intended, stakeholders reported operational challenges including ACE access issues, user confusion, questions regarding interest calculations, and ongoing concerns with ineligible or complex entry types.
May 2026	May 11, 2026	CBP provided update to CIT on CAPE processing status.	CBP received 126,237 CAPE declarations, of which 86,874 successfully passed file validation requirements. Those validated declarations included approximately 15.1 million entries accepted for IEEPA duty removal processing through CAPE, with approximately 8.34 million entries already liquidated and/or reliquidated without IEEPA duties, representing an estimated $35.46 billion in duty refunds and interest. CBP also reported that 1,880 consolidated refunds remain pending transmission to the U.S. Treasury due to missing ACH information from the IOR or an authorized CBP Form 4811 designee.
	May 26, 2026	CBP provided update to CIT on CAPE processing status.	CBP reported that more than 157,000 CAPE declarations had been submitted as of May 26, with approximately $85 billion in IEEPA refunds accepted for processing and $20.6 billion already processed through the CAPE Refund component.
	May 27, 2026	CIT questions ongoing suspension of universal refund order.	During a May 27 conference, the CIT reviewed ongoing importer challenges with CAPE, including issues involving HTSUS 9817 claims, and questioned CBP's continued suspension of the Court's order directing refunds for all affected importers. The Court also ordered CBP to provide its next CAPE progress update by June 10.
June 2026	June 10, 2026	CBP reports nearly $95 billion in accepted IEEPA refunds and announces CAPE Phase 2 & 3 timeline.	CBP reported that more than 180,000 CAPE declarations had been submitted as of June 10, with approximately $94.94 billion in IEEPA refunds accepted for processing and $23.68 billion already refunded through the CAPE Refund component. CBP also announced that CAPE Phase 2 is expected to launch on June 29 to support reconciliation entries, with Phase 3 anticipated in late July to expand processing to additional entry types, including those associated with CIT litigation. Meanwhile, the government continues to challenge the CIT's authority to order nationwide IEEPA refunds while maintaining that additional time is needed to implement functionality for more complex entry categories.

Start your IEEPA refund claim

As CAPE functionality continues to expand, importers should begin evaluating eligible entries and developing a refund strategy before key filing deadlines pass. Baker Tilly's Global Trade Advisory team can help assess CAPE eligibility, prioritize claims, coordinate reconciliation strategies and navigate the evolving refund process.

Ready to get started? Contact our Global Trade Management team to start your IEEPA refund claim.

Start here

References and resources

[1] https://www.cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds

[2] https://www.cbp.gov/trade/automated/how-to-use-ace/portal-applying

[3] https://www.cbp.gov/document/guidance/trade-information-notice-cape

[4] https://www.cbp.gov/sites/default/files/2026-04/ace_portal_cape_qrg_trade_0.pdf

Pete Mento

Director

Tosca Derrick

Director

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The information provided here is of a general nature and is not intended to address the specific circumstances of any individual or entity. In specific circumstances, the services of a professional should be sought. Tax information, if any, contained in this communication was not intended or written to be used by any person for the purpose of avoiding penalties, nor should such information be construed as an opinion upon which any person may rely. The intended recipients of this communication and any attachments are not subject to any limitation on the disclosure of the tax treatment or tax structure of any transaction or matter that is the subject of this communication and any attachments.

Month	Date	Event or milestone	Key outcomes and notes
February 2025	February 4, 2025	IEEPA duties became applicable to covered imports entered for consumption on or after this date.	For customs purposes, applicability is based on the entry date or warehouse withdrawal date, not ship or arrival date. Applicable rates varied by country of origin and Executive Order in effect at entry.
February 2026	February 20, 2026	U.S. Supreme Court held that use of IEEPA to impose certain tariffs was unlawful.	Following the decision, the CIT directed CBP to establish refund procedures. Importers became legally entitled to pursue refunds once CBP procedures were published.
March 2026	March 2, 2026	Federal Circuit denied DOJ request for delay and returned case to the CIT.	CIT regained authority to define IEEPA refund mechanics.
	March 4, 2026	Judge Richard Eaton ordered CBP to process unliquidated entries without IEEPA tariffs and reliquidate non-final liquidated entries.	CBP also ordered to explain refund and reliquidation procedures.
	March 6, 2026	CBP Executive Director Brandon Lord filed response outlining operational challenges with immediate refunds.	CBP estimated manual processing would require 4.4+ million labor hours for 53+ million entries. Proposed automated ACE-based refund process with tentative launch target of April 20, 2026. CIT paused immediate refund requirement.
	March 12, 2026	CBP formally introduced the CAPE (Consolidated Administration and Processing of Entries) system within ACE.	CAPE designed to automate refund requests, recalculations, liquidation/reliquidation, and refunds. Four components introduced: Claim portal, Mass processing, Review & liquidation/reliquidation, and Refund processing. Components estimated 40% - 80% complete.
	March 19, 2026	CBP provided CAPE development progress update.	Overall completion increased from 63% to 65%. Claim portal: 73%, Mass processing: 45%, Refund processing: 63%, Review & liquidation/re-Liquidation: 80%.
	March 20, 2026	CIT confirmed all IEEPA tariffs, including Brazil and India tariffs, are eligible for refunds.	CBP ordered to provide additional CAPE progress report by March 31, 2026.
	March 27, 2026	CIT expanded on their March 4th order to include finally liquidated entries.	CBP ordered to broaden IEEPA refund scope to those entries that have completed both the 314-day liquidation cycle and the 180-day protest period.
	March 31, 2026	CBP reported CAPE Phase 1 approximately 75% complete and outlined Phase 1 scope and exclusions.	Scope included unliquidated entries and entries within voluntary reliquidation window. Expanded functionality added warehouse and suspended entries. Exclusions included finally liquidated entries, drawback, protest, AD/CVD, and non-ACE entries.
April 2026	April 10, 2026	CBP issued CSMS #68315804 confirming April 20 launch of CAPE Phase 1.	Confirmed ACE portal and ACH enrollment requirements. Refunds to be consolidated rather than entry-by-entry.
	April 13, 2026	CBP issued CSMS #68340863 with operational guidance for CAPE deployment.	Guidance detailed CSV bulk filing process, automated validation, refund processing timelines, ACH refunds, and operational restrictions for protests, drawbacks, PSC filings, and AD/CVD entries.
	April 14, 2026	CBP reported CAPE Phase 1 reached approximately 90% completion.	Claim portal: 95%, Mass processing: 85%, Review & liquidation/reliquidation: 90%, Refund processing: 90%. Final testing underway. Approximately 82% of IEEPA refunds (~$127B) expected to process via ACH automation.
	April 20, 2026	CBP issued CSMS #68396594 announcing CAPE Phase 1 is live in ACE.	Importers and authorized customs brokers may now file CAPE declarations through ACE portal accounts. CAPE consolidates IEEPA duty refunds, including interest, rather than processing refunds entry-by-entry. Phase 1 is limited to certain unliquidated entries and certain entries within 80 days of liquidation. Supporting resources released by CBP include the CAPE information notice [3], ACE portal: CAPE declarations quick reference guide [4], and the IEEPA duty refunds page [1].
	April 28, 2026	CBP provided update to the CIT on CAPE processing status.	Approximately 11 million entries were accepted by CAPE and passed entry-specific validations. Of those, about 1.74 million entries have been liquidated and entered the refund process. While the system is generally functioning as intended, stakeholders reported operational challenges including ACE access issues, user confusion, questions regarding interest calculations, and ongoing concerns with ineligible or complex entry types.
May 2026	May 11, 2026	CBP provided update to CIT on CAPE processing status.	CBP received 126,237 CAPE declarations, of which 86,874 successfully passed file validation requirements. Those validated declarations included approximately 15.1 million entries accepted for IEEPA duty removal processing through CAPE, with approximately 8.34 million entries already liquidated and/or reliquidated without IEEPA duties, representing an estimated $35.46 billion in duty refunds and interest. CBP also reported that 1,880 consolidated refunds remain pending transmission to the U.S. Treasury due to missing ACH information from the IOR or an authorized CBP Form 4811 designee.
	May 26, 2026	CBP provided update to CIT on CAPE processing status.	CBP reported that more than 157,000 CAPE declarations had been submitted as of May 26, with approximately $85 billion in IEEPA refunds accepted for processing and $20.6 billion already processed through the CAPE Refund component.
	May 27, 2026	CIT questions ongoing suspension of universal refund order.	During a May 27 conference, the CIT reviewed ongoing importer challenges with CAPE, including issues involving HTSUS 9817 claims, and questioned CBP's continued suspension of the Court's order directing refunds for all affected importers. The Court also ordered CBP to provide its next CAPE progress update by June 10.
June 2026	June 10, 2026	CBP reports nearly $95 billion in accepted IEEPA refunds and announces CAPE Phase 2 & 3 timeline.	CBP reported that more than 180,000 CAPE declarations had been submitted as of June 10, with approximately $94.94 billion in IEEPA refunds accepted for processing and $23.68 billion already refunded through the CAPE Refund component. CBP also announced that CAPE Phase 2 is expected to launch on June 29 to support reconciliation entries, with Phase 3 anticipated in late July to expand processing to additional entry types, including those associated with CIT litigation. Meanwhile, the government continues to challenge the CIT's authority to order nationwide IEEPA refunds while maintaining that additional time is needed to implement functionality for more complex entry categories.

Month

Date

Event or milestone

Key outcomes and notes

February 2025

February 4, 2025

IEEPA duties became applicable to covered imports entered for consumption on or after this date.

For customs purposes, applicability is based on the entry date or warehouse withdrawal date, not ship or arrival date. Applicable rates varied by country of origin and Executive Order in effect at entry.

February 2026

February 20, 2026

U.S. Supreme Court held that use of IEEPA to impose certain tariffs was unlawful.

Following the decision, the CIT directed CBP to establish refund procedures. Importers became legally entitled to pursue refunds once CBP procedures were published.

March 2026

March 2, 2026

Federal Circuit denied DOJ request for delay and returned case to the CIT.

CIT regained authority to define IEEPA refund mechanics.

March 4, 2026

Judge Richard Eaton ordered CBP to process unliquidated entries without IEEPA tariffs and reliquidate non-final liquidated entries.

CBP also ordered to explain refund and reliquidation procedures.

March 6, 2026

CBP Executive Director Brandon Lord filed response outlining operational challenges with immediate refunds.

CBP estimated manual processing would require 4.4+ million labor hours for 53+ million entries. Proposed automated ACE-based refund process with tentative launch target of April 20, 2026. CIT paused immediate refund requirement.

March 12, 2026

CBP formally introduced the CAPE (Consolidated Administration and Processing of Entries) system within ACE.

CAPE designed to automate refund requests, recalculations, liquidation/reliquidation, and refunds. Four components introduced: Claim portal, Mass processing, Review & liquidation/reliquidation, and Refund processing. Components estimated 40% - 80% complete.

March 19, 2026

CBP provided CAPE development progress update.

Overall completion increased from 63% to 65%. Claim portal: 73%, Mass processing: 45%, Refund processing: 63%, Review & liquidation/re-Liquidation: 80%.

March 20, 2026

CIT confirmed all IEEPA tariffs, including Brazil and India tariffs, are eligible for refunds.

CBP ordered to provide additional CAPE progress report by March 31, 2026.

March 27, 2026

CIT expanded on their March 4th order to include finally liquidated entries.

CBP ordered to broaden IEEPA refund scope to those entries that have completed both the 314-day liquidation cycle and the 180-day protest period.

March 31, 2026

CBP reported CAPE Phase 1 approximately 75% complete and outlined Phase 1 scope and exclusions.

Scope included unliquidated entries and entries within voluntary reliquidation window. Expanded functionality added warehouse and suspended entries. Exclusions included finally liquidated entries, drawback, protest, AD/CVD, and non-ACE entries.

April 2026

April 10, 2026

CBP issued CSMS #68315804 confirming April 20 launch of CAPE Phase 1.

Confirmed ACE portal and ACH enrollment requirements. Refunds to be consolidated rather than entry-by-entry.

April 13, 2026

CBP issued CSMS #68340863 with operational guidance for CAPE deployment.

Guidance detailed CSV bulk filing process, automated validation, refund processing timelines, ACH refunds, and operational restrictions for protests, drawbacks, PSC filings, and AD/CVD entries.

April 14, 2026

CBP reported CAPE Phase 1 reached approximately 90% completion.

Claim portal: 95%, Mass processing: 85%, Review & liquidation/reliquidation: 90%, Refund processing: 90%. Final testing underway. Approximately 82% of IEEPA refunds (~$127B) expected to process via ACH automation.

April 20, 2026

CBP issued CSMS #68396594 announcing CAPE Phase 1 is live in ACE.

Importers and authorized customs brokers may now file CAPE declarations through ACE portal accounts. CAPE consolidates IEEPA duty refunds, including interest, rather than processing refunds entry-by-entry. Phase 1 is limited to certain unliquidated entries and certain entries within 80 days of liquidation. Supporting resources released by CBP include the CAPE information notice [3], ACE portal: CAPE declarations quick reference guide [4], and the IEEPA duty refunds page [1].

April 28, 2026

CBP provided update to the CIT on CAPE processing status.

Approximately 11 million entries were accepted by CAPE and passed entry-specific validations. Of those, about 1.74 million entries have been liquidated and entered the refund process. While the system is generally functioning as intended, stakeholders reported operational challenges including ACE access issues, user confusion, questions regarding interest calculations, and ongoing concerns with ineligible or complex entry types.

May 2026

May 11, 2026

CBP provided update to CIT on CAPE processing status.

CBP received 126,237 CAPE declarations, of which 86,874 successfully passed file validation requirements. Those validated declarations included approximately 15.1 million entries accepted for IEEPA duty removal processing through CAPE, with approximately 8.34 million entries already liquidated and/or reliquidated without IEEPA duties, representing an estimated $35.46 billion in duty refunds and interest. CBP also reported that 1,880 consolidated refunds remain pending transmission to the U.S. Treasury due to missing ACH information from the IOR or an authorized CBP Form 4811 designee.

May 26, 2026

CBP provided update to CIT on CAPE processing status.

CBP reported that more than 157,000 CAPE declarations had been submitted as of May 26, with approximately $85 billion in IEEPA refunds accepted for processing and $20.6 billion already processed through the CAPE Refund component.

May 27, 2026

CIT questions ongoing suspension of universal refund order.

During a May 27 conference, the CIT reviewed ongoing importer challenges with CAPE, including issues involving HTSUS 9817 claims, and questioned CBP's continued suspension of the Court's order directing refunds for all affected importers. The Court also ordered CBP to provide its next CAPE progress update by June 10.

June 2026

June 10, 2026

CBP reports nearly $95 billion in accepted IEEPA refunds and announces CAPE Phase 2 & 3 timeline.

CBP reported that more than 180,000 CAPE declarations had been submitted as of June 10, with approximately $94.94 billion in IEEPA refunds accepted for processing and $23.68 billion already refunded through the CAPE Refund component. CBP also announced that CAPE Phase 2 is expected to launch on June 29 to support reconciliation entries, with Phase 3 anticipated in late July to expand processing to additional entry types, including those associated with CIT litigation. Meanwhile, the government continues to challenge the CIT's authority to order nationwide IEEPA refunds while maintaining that additional time is needed to implement functionality for more complex entry categories.