Tariff Refund Process Begins as United States Customs and Border Protection (CBP) Launches the Consolidated Administration and Processing of Entries (CAPE) Portal

Following the Supreme Court’s decision earlier this year that struck down tariffs imposed under the International Emergency Economic Powers Act (IEEPA), U.S. Customs and Border Protection (CBP) has begun implementing a formal refund process.

CBP has introduced a new system, the Consolidated Administration and Processing of Entries (CAPE), to facilitate the refund process. The CAPE portal opened on April 20, 2026, and importers have started submitting claims.

The CAPE system is intended to streamline what would otherwise be a lengthy, entry-by-entry refund process. Importers can submit batches of eligible entries through the Automated Commercial Environment (ACE) Portal, after which CBP will recalculate duties and issue refunds, including applicable interest, via electronic payment.

What Should Importers Do Now?

Importers should first confirm that they are properly set up within CBP’s systems. This includes having an active ACE Portal account and ensuring that Automated Clearing House (ACH) payment information is correctly configured. Without these steps, refunds may be delayed even if claims are approved.

Companies should also begin identifying entries that may qualify for refunds. Phase 1 of the CAPE rollout applies to certain entries that include IEEPA tariff codes and meet specific timing criteria.

Key steps may include:

• Compiling a list of potentially eligible entries
• Reconciling broker data with internal records
• Confirming that entries meet CAPE eligibility criteria

Should Entries Be Reviewed Before Filing?

Entries should be carefully reviewed prior to being submitted for refund claims. Once a CAPE filing is submitted, it may not be easily modified.  As part of this process, CBP is reviewing entries for accuracy.

Potential issues that may arise include:

• Errors in tariff classification
• Incorrect valuation of imported goods
• Country of origin discrepancies
• Delays or adjustments to refund amounts

To avoid rejection for any of these issues, companies are carefully reviewing their entries in advance, to identify potential issues before filing. A structured review process will help reduce risk and improve the accuracy of refund claims.

What Comes Next?

The refund process is now underway, though additional guidance from CBP and the courts may continue to evolve. Processing timelines will vary, and refunds may be subject to review or offset against other outstanding obligations.

Companies that imported goods subject to IEEPA tariffs should:

• Confirm system readiness within the ACE Portal
• Coordinate with customs brokers and advisors
• Evaluate eligibility for refunds and calculate amount to be refunded
• Review entry data prior to submission

Given the scale of potential refunds and the complexity of the process, it is important to approach filings carefully. LMC will continue to monitor developments and provide updates as guidance evolves.