CBP CAPE Tool Goes Live April 20, 2026: How to File Your IEEPA Tariff Refund in Phase 1
CBP CAPE Tool Goes Live April 20, 2026: How to File Your IEEPA Tariff Refund in Phase 1
U.S. Customs and Border Protection confirmed on April 10, 2026 that the first phase of its automated IEEPA tariff refund process will launch on April 20, 2026. The tool is called the Consolidated Administration and Processing of Entries (CAPE), and it will live inside the Automated Commercial Environment (ACE) portal that customs brokers and importers of record already use for daily entry filings.
Phase 1 is narrow but important. It is the first chance for roughly 330,000 importers to begin recovering the approximately $166 billion in IEEPA-based duties that the Supreme Court ruled unlawful in *Learning Resources v. Trump* on February 20, 2026. This article breaks down exactly what Phase 1 covers, which entries qualify, how the CAPE Declaration process works, and what importers should do between now and April 20 to be ready to file on day one.
What Phase 1 Actually Covers
CBP structured the refund rollout in phases to manage volume and reduce error rates on the most complex refund scenarios. Phase 1 is limited to two entry categories:
Unliquidated entries. If an entry assessing IEEPA duties has not yet been liquidated by CBP, it is eligible for Phase 1. CAPE will accept a CAPE Declaration, strip out the IEEPA tariff classifications, and reliquidate the entry at the correct non-IEEPA duty total. Because unliquidated entries have not been finalized, there is no protest clock and no competing reconciliation issue to manage — these are the cleanest refunds in the system.
Entries within 80 days of liquidation. Entries that have been liquidated but are still within a defined 80-day window are also eligible in Phase 1. CBP chose the 80-day window because it keeps Phase 1 refunds inside the standard 180-day protest window under 19 U.S.C. § 1514, providing a clean legal path to reverse the liquidation and recalculate the duty amount without relying on any special administrative authority.
More complex scenarios — entries liquidated beyond 80 days, entries tied up in protest proceedings, entries interacting with drawback claims or Foreign Trade Zone admissions, and entries involving post-summary corrections — are deferred to later phases. CBP has not yet announced firm dates for Phase 2 or Phase 3, but industry sources expect the rollout to continue through the summer and into the fall of 2026.
How the CAPE Declaration Process Works
The CAPE Declaration is the single filing that triggers the refund workflow. It is filed by the importer of record or a licensed customs broker acting on their behalf, directly inside ACE. The filer identifies the entries they believe are eligible for refund and submits them under a CAPE case. CBP then:
1. Validates that the entries fall within Phase 1 eligibility. 2. Removes the IEEPA tariff line items from each entry. 3. Recalculates the total duty owed using only the non-IEEPA layers (MFN base duty, Section 301, Section 232, and — for entries after February 24, 2026 — Section 122). 4. Consolidates refunds by liquidation date and importer of record. 5. Issues the refund via the importer's ACH account on file with CBP.
According to CBP, refunds "will generally be issued within 60–90 days following acceptance of a CAPE Declaration, unless a compliance concern requires further CBP review." In practice, straightforward declarations without compliance flags may see payment in as little as 45 days from filing.
A Concrete Example
Consider a Charleston importer who brought in $2 million in Vietnamese apparel during October 2025. At that time, the applicable IEEPA rate on Vietnam was 20%, so the importer paid $400,000 in IEEPA duties on top of the 16% MFN rate ($320,000) and a 10% reciprocal surcharge baked into the IEEPA structure.
If those October entries are still unliquidated, or if they were liquidated within the 80-day window (i.e. on or after roughly February 1, 2026), the importer can file a CAPE Declaration on April 20 and expect a refund of the full $400,000 plus statutory interest within 60–90 days. That is real working capital coming back, and in Phase 1 it requires nothing more than a single filing from the customs broker.
Entries from earlier in 2025 — such as April or May entries that were liquidated well before February 2026 — fall outside Phase 1 and must wait for a later phase or be pursued through the standard protest process.
How This Interacts With Section 122
One common question: does filing a CAPE Declaration affect the Section 122 duty the importer is paying on entries after February 24, 2026? The answer is no. Section 122 is a legally distinct surcharge under the Trade Act of 1974 and is not part of the IEEPA refund process. Entries entered on or after February 24, 2026 still owe the 10% Section 122 tariff, and that duty amount stays in place when the CAPE tool recalculates the entry. Only the IEEPA line items are removed.
For a broader discussion of how the current tariff layers stack, see our Tariff Stacking in 2026 article, and use the Duty & Tariff Calculator to estimate your current landed costs under Section 301, Section 232, and Section 122 as they apply today.
What Importers Should Do Between Now and April 20
Confirm importer of record status. CAPE refunds flow to the importer of record identified on each entry. If your company used a different legal entity or a broker-of-record arrangement during 2025, verify which entity is expected to receive the refund.
Pull an IEEPA-duty-only entry report from your broker. Ask your customs broker to generate a report of every entry filed between March 2025 and February 24, 2026, showing the IEEPA portion of duty separately from other layers. This is the data you will need to identify Phase 1-eligible entries on day one.
Identify Phase 1-eligible entries specifically. Flag entries that are either (a) still unliquidated or (b) liquidated within 80 days of April 20 — meaning liquidated on or after approximately January 31, 2026. These are the entries ready for immediate CAPE filing.
Verify ACH information in ACE. Refunds issue via ACH to the bank account on file. If your banking information has changed in the last 12 months, update ACE now to avoid a delayed or rejected refund payment.
Coordinate filing authority with your broker. Decide in advance whether you will file CAPE Declarations yourself or authorize your broker to file on your behalf. Put the decision in writing so there is no ambiguity on April 20.
The Bigger Picture
CAPE is the first step of a very large payout — $166 billion across roughly 330,000 importers is one of the largest duty-refund processes in U.S. customs history. Phase 1 will process the cleanest subset of those entries, and importers with clean, recent, Phase 1-eligible entries stand to see refunds land in the summer of 2026.
For more background on the full IEEPA refund landscape, including eligibility details and the Section 122 replacement regime, see our Complete 2026 IEEPA Tariff Refund Guide. And use the Duty & Tariff Calculator to keep your go-forward landed cost estimates accurate as the tariff regime continues to evolve.
Frequently Asked Questions
Common questions about cbp cape tool goes live april 20, 2026
When does the CBP CAPE tool go live?
CBP confirmed on April 10, 2026 that Phase 1 of the IEEPA tariff refund process through the CAPE (Consolidated Administration and Processing of Entries) tool launches on April 20, 2026, inside the ACE portal.
Which entries are eligible for Phase 1?
Phase 1 covers unliquidated entries and entries liquidated within the past 80 days. More complex scenarios — older liquidated entries, protest-pending entries, drawback and FTZ interactions — are deferred to later phases.
How long does a CAPE refund take?
CBP states that refunds will generally be issued within 60–90 days after a CAPE Declaration is accepted, assuming no compliance review is required. Clean declarations without flags may pay out in as little as 45 days.
Does CAPE affect my Section 122 duties?
No. Section 122 is a separate legal authority under the Trade Act of 1974 and is not part of the IEEPA refund process. Entries filed on or after February 24, 2026 continue to owe the 10% Section 122 tariff, and that duty remains when CAPE recalculates the entry.
Do I need to file anything to get a Phase 1 refund?
Yes. Phase 1 is not automatic — the importer of record or a licensed customs broker must file a CAPE Declaration inside ACE identifying the eligible entries. Unlike later automated phases CBP has discussed, the Phase 1 workflow is declaration-driven.
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