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IEEPA Tariff Refunds

IEEPA duty refund readiness: organize entries before submitting a request

U.S. Customs and Border Protection has established the Consolidated Administration and Processing of Entries system—CAPE—for eligible IEEPA duty refund requests. Importers and authorized brokers should prepare accurate data before filing.

July 30, 20268 min readWe Incentivize Trade Advisory
Import and customs data review for an IEEPA duty refund article

Educational content from We Incentivize. Tax, legal, accounting, customs, and grant conclusions depend on the specific facts and current guidance.

Key takeaways

  • Confirm the importer, entries, duty types, and authority to request the refund.
  • Reconcile entry data and prior adjustments before submission.
  • Maintain ACE Portal access and current ACH banking information.
  • Monitor CBP guidance because process phases and requirements can change.
01

Understand the CAPE process

CBP describes CAPE as the ACE Portal pathway for IEEPA duty refund requests made under the applicable court and agency process. Filing rules, phases, and eligibility requirements are controlled by CBP guidance.

Importers should review the current fact sheets, trade notices, and FAQs rather than relying on informal summaries.

Only eligible importers or authorized representatives should submit requests, and each request must match CBP's current requirements.

02

Build a clean entry population

Start with entry numbers, importer-of-record numbers, lines, dates, duty amounts, tariff measures, liquidation status, protests, post-summary corrections, and any prior refunds or adjustments.

The population should reconcile to the company's customs records and general ledger. Duplicate or incomplete records can delay the analysis.

  • Entry summary and line-level data
  • IEEPA duty amounts paid
  • Liquidation and protest status
  • Prior corrections, refunds, and drawback activity
  • Broker and importer records
03

Confirm authority and account access

The company should identify who is authorized to act, confirm broker powers of attorney where relevant, and verify ACE Portal access. Internal legal, trade, finance, and treasury teams may all have responsibilities.

CBP also states that refunds are paid through ACH, so bank account information must be current.

  • Importer authorization and broker documentation
  • ACE Portal user access
  • ACH refund enrollment and bank details
  • Internal approval and record-retention process
04

Reconcile the claim before submission

The requested amount should tie to source entries and account for prior events. The company should preserve a clear calculation workbook and supporting documents.

A review should also consider whether other customs programs or pending actions affect the same entries.

  • Trace every requested amount to an entry line
  • Remove duplicate or previously refunded amounts
  • Document exclusions and unresolved items
  • Retain submission confirmation and CBP correspondence
05

Monitor status and changing guidance

CBP states that valid refunds are generally expected within a stated period after acceptance, but actual timing depends on the request and agency processing. Companies should maintain a status log and reconcile receipts when issued.

This article is general information and does not determine eligibility or create a customs claim. Consult qualified customs and legal advisors and follow current CBP instructions.