IEEPA Tariff Refunds via CAPE: Where Things Stand

Following the U.S. Supreme Court's invalidation of the Trump administration's tariff program under the International Emergency Economic Powers Act (IEEPA), U.S. Customs and Border Protection (CBP) has been moving quickly to return billions of dollars in duties to American importers.

What Is CAPE?

CBP developed the Consolidated Administration and Processing of Entries (CAPE) to streamline the submission and processing of IEEPA duty refund requests. Rather than handling refunds on an entry-by-entry basis, CAPE consolidates claims across thousands of entries at once.

Phase 1: Now Active

Phase 1 of CAPE went live on April 20, 2026, and as of May 11, 2026, more than 126,000 CAPE declarations had been submitted, covering over 15 million individual entries. Of those, roughly 8.3 million entries had been liquidated or reliquidated with anticipated refunds and interest totaling approximately $35.46 billion.

ACH refund payments began as early as May 12, 2026, with some importers already receiving funds directly to their bank accounts. CBP has said importers should generally expect refunds within 60–90 days of an accepted CAPE Declaration.

As Allyn has seen refunds begin to come for our clients, we built a tool to help track the refunds. Based on the ES-022 (CAPE Entry Summary Report) from ACE, the tool shows the refund status of CAPE filings.

What About Phase 2?

CAPE Phase 2 is the upcoming, anticipated second stage of U.S. Customs and Border Protection's (CBP) IEEPA duty refund process. While Phase 1 covers unliquidated entries and those within standard voluntary liquidation/protest windows, Phase 2 is expected to unlock refunds for liquidated entries and more complex claims. CBP has not yet announced a launch date for Phase 2.

For those with eligible Phase 1 entries who haven't yet filed, time is of the essence, refunds won't come automatically, and entries must be actively submitted through the ACE Portal.

At Allyn International, we are committed to supporting the global trade community with strategic, forward-thinking solutions to help navigate today’s complex tariff landscape. If you have questions about tariffs or would like to explore strategies to reduce their impact on your business operations, our team is here to help. Contact us today for a consultation at  sales@allynintl.com

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About Allyn International

Allyn International provides high quality, customer centric services and solutions for the global marketplace. Allyn's core products include transportation management, logistics sourcing, freight forwarding, supply chain consulting, tax management and global trade compliance. Allyn clients range from small local businesses to Fortune 500 firms. Allyn conducts business in more than 20 languages and has extensive experience in both developed and emerging markets. Highly trained experts are positioned throughout North and South America, Europe and Asia. Allyn’s regional headquarters are strategically located in Fort Myers, Florida, U.S.A., Shanghai, P.R. China, Prague, Czech Republic, and Dubai, U.A.E. For more information, visit www.allynintl.com.