How CBP Processes IEEPA Refunds Through the CAPE System

The importer of record (IOR) or their licensed customs broker logs into the ACE Secure Data Portal and navigates to the CAPE tab. The IOR or broker downloads the CAPE Declaration upload template — a single-column CSV with 'Entry Number' in Row 1 and entry numbers in subsequent rows. Each Declaration is limited to 9,999 entries; multiple Declarations may be submitted. Before uploading, the submitter should verify: all entry numbers exist in ACE; all entries have at least one dutiable IEEPA Chapter 99 HTS code; no entry number appears more than once across all Declarations; entry types are eligible for the active phase (no Types 21/22 after July 7, 2026 per CSMS #69127837; no entries with a filed Type 09 for Phase 2 filings); and ACH banking information is enrolled in ACE. Declarations cannot be amended once accepted — additional entries require a new Declaration.

Upon upload, ACE performs the first of two sequential validation series against the CAPE Declaration file itself. File-level validation confirms: (1) the submitter is either the IOR for the listed entries or the customs broker who filed the entry summaries; (2) the Declaration includes a list of entry numbers; and (3) the file format is correct CSV with no structural errors. If the file fails any file-level check, ACE rejects the entire Declaration. A Validation Result File can be downloaded from the File Upload Status column in the CAPE tab — it identifies the specific errors. The corrected Declaration must be resubmitted as a new file. There is no amendment process for rejected Declarations.

For Declarations that pass file-level validation, ACE performs entry-level validation on each individual entry number listed. Entry-level checks confirm: (1) the entry summary exists in ACE; (2) at least one dutiable IEEPA Chapter 99 HTS code was declared on the entry; and (3) no entry number is duplicated in the same or a prior Declaration. Entries that fail entry-level validation are rejected individually — valid entries in the same Declaration continue to process. Importers can review per-entry validation results in the CAPE Claim Status section by selecting the applicable claim number and downloading the results file. As of June 29, 2026, 4.36 million entries across the program have failed entry-level validation. Common causes: no Chapter 99 code on the entry, duplicate entry number, wrong entry type for the active phase.

For entries that pass both validation series, ACE updates the entry summary lines to remove the dutiable IEEPA Chapter 99 HTS codes and recalculates duties owed without them. This generates a new version of the entry summary. CBP then liquidates or reliquidates the entry — issuing a final determination that the IEEPA duties are not owed. The difference between the original duty amount and the recalculated amount (zero IEEPA duties) becomes the refund principal. Note: some entries were originally filed with combined duty reporting under Framework Agreements (EU, Japan, South Korea, Switzerland) where IEEPA and Column 1 duties were reported at a combined 15% ceiling. CBP's recalculation may differ from a straightforward subtraction in these cases — verify with your broker.

After reliquidation, CBP consolidates approved refunds by importer of record and liquidation date. The consolidated refund amount — duty principal plus statutory interest under 19 U.S.C. § 1505 — is certified and transmitted to the U.S. Department of the Treasury for ACH disbursement. Treasury issues the ACH payment to the bank account on file in ACE for the IOR (or the Form 4811 designee's account if one has been designated). As of June 29, 2026: $71.06 billion has been certified and sent to Treasury. Of that, 8,384 certified refunds are stuck at Treasury solely because the importer or designee never provided ACH banking information. If you are waiting for payment, log into ACE and verify your ACH enrollment immediately. CBP does not provide a guaranteed disbursement timeline, but the working estimate is 60–90 days from validated Declaration to ACH receipt.

Log into your ACE Secure Data Portal account and navigate to the CAPE tab. The CAPE Claim Status section shows the current status of each Declaration and the per-entry validation results. The ACE CAPE dashboard displays: your Declaration number, file upload status, validation result summary, number of accepted entries, number of rejected entries, approved refund amount, and disbursement status. For entries that failed validation, download the Validation Result File to identify the specific rejection reason for each entry number. Correctable failures (missing ACH, wrong entry type) can be remedied and resubmitted in a new Declaration. Non-correctable failures (no Chapter 99 code on the original entry) may require a Post-Summary Correction before resubmission — consult your licensed customs broker.