U.S. Customs and Border Protection (CBP) has implemented a process for importers to recover duties paid under the International Emergency Economic Powers Act (IEEPA).
This update outlines the refund opportunity, Phase 1 eligibility, and key next steps.
Opportunity to Claim Refunds
Importers of Record (IORs) that paid IEEPA duties may be eligible to recover those amounts, including interest.
Refunds are not automatic. A formal claim must be submitted through CBP’s system using the CAPE (Consolidated Administration and Processing of Entries) module in ACE.
CBP opened the CAPE refund process on April 20, 2026, enabling eligible importers and brokers to begin submitting Phase 1 claims.
Phase 1 Eligibility
CBP will process requests and issue IEEPA duty refunds in phases, beginning with the most straightforward claims.
Phase 1 includes:
- Certain unliquidated entries where IEEPA duties were paid
- Certain entries within 80 days of liquidation
For context, liquidation is the point at which CBP finalizes an entry by confirming the classification, value, and duty owed. Once an entry liquidates, the duty amount becomes final unless timely action is taken.
Entries are typically liquidated approximately 314 days from the date of entry, unless extended or suspended.
Additional phases are expected to expand eligibility to other entries and timeframes.
How to Submit a Claim
Importers interested in making a refund claim must submit a CAPE declaration through CBP’s ACE portal. While importers may submit claims directly, most importers will prefer to work with their customs broker. Importers should contact their broker to review eligibility and coordinate submission.
The process includes:
- Identify Eligible Entries
Confirm IEEPA duties were paid, and Phase 1 criteria are met. - Prepare CAPE Submission
Compile eligible entries in the required CSV format. - Submit via ACE
File the CAPE declaration through the ACE portal (by the importer or authorized broker). - Ensure ACE ACH Setup is Complete
Make sure an ACE account is configured to receive ACH refund payments. - Monitor Status
Track submission and payment through ACE after filing.
Next Steps
Importers that may be eligible for an IEEPA duty refund should act promptly. While direct submission is possible, working with a customs broker can help streamline eligibility review, submission preparation, and filing through ACE.
We recommend contacting your broker to:
- Review potentially eligible entries.
- Confirm Phase 1 eligibility.
- Determine next steps for submitting a CAPE claim.
Early coordination will help ensure timely submission and reduce the risk of delays as CBP expands the program. For more information, refer to CBP’s International Emergency Economic Powers Act (IEEPA) Duty Refunds page: International Emergency Economic Powers Act (IEEPA) Duty Refunds.
For questions regarding this guidance or IEEPA refunds, please contact Tradecompliance@marken.com.
