Customs’ new tariff refund system presents a major cash flow recovery opportunity for importers, but many are still navigating exactly how it works. As of April 26, the agency said it had processed more than 11.2 million entries across more than 75,000 submissions, only 63% of which had passed the first validation step.
To address the most common questions importers face, Grassi Manufacturing & Distribution Partner Michael Violano recently hosted the webinar, IEEPA Tariff Refunds: What Phase 1 Means for Importers, with licensed customs broker and Co-CEO of Cargo Trans, Nunzio Di Filipe. Below, we share the key takeaways from the discussion.
For additional background on earlier developments, see Grassi’s prior coverage on how the system works and what importers should know now that it is live.
What is CAPE?
U.S. Customs and Border Protection (CBP) developed the Consolidated Administrative and Processing of Entries (CAPE) system to manage an estimated $166 billion in International Emergency Economic Powers Act (IEEPA) tariff refunds owed to more than 330,000 importers. CAPE operates within the Automated Commercial Environment (ACE) portal as a separate processing layer, consolidating claims by the Importer of Record (IOR) and liquidation date to recalculate duties in bulk.
Which Tariffs are Refundable?
CAPE broadly covers reciprocal tariffs imposed under Executive Order 14257 (a baseline rate of 10%, plus country-specific rates adjusted throughout the year), as well as separate emergency duties levied on imports from China, Canada and Mexico. CAPE does not accept claims for duties under Section 232, Section 301 or Section 122, though the legislative and trade landscape continues to evolve.
Which Entries Qualify Under Phase 1?
Phase 1 launched on April 20, 2026, and applies to unliquidated entries and entries liquidated within the prior 80 days. Reconciliation entries, drawback-related entries, unresolved protests and certain antidumping or countervailing duty (AD/CVD) entries will be addressed in later phases. For the full list of eligible and excluded entry types, refer to CBP’s IEEPA Duty Refunds page.
Who Can File?
Only the IOR or a licensed customs broker who filed entries on the IOR’s behalf may submit a CAPE declaration. Refunds are issued to the IOR or to a designated party through CBP Form 4811. Importers who switched to Delivered Duty Paid (DDP) terms during the tariff period should review their IOR status, as DDP may have transferred that designation to the foreign shipper.
Balancing Expediency and Accuracy: How to Submit CAPE Claims
Importers submit refund claims by uploading a .CSV file containing entry numbers. After acceptance, CBP removes the IEEPA tariff codes, recalculates duties, and moves entries into liquidation or reliquidation for in-depth review.
Though CBP has announced no “cutoff” date for CAPE uploads, the 80-day reliquidation window for Phase 1 creates some urgency. In many cases, a phased, strategic approach can reduce risk and help importers prioritize their claims:
- Adopt a phased approach: Start with lower-risk entries where classification, valuation and origin are fully confirmed, then move to larger, more complex entries with additional preparation. Consider reinvesting early refund proceeds, including 6% interest for corporate filers, toward compliance reviews for remaining entries.
- Plan for cash flow timing: CBP estimates 60 to 90 days from acceptance to payment. Importers managing a quarterly close should plan for when refund income will be recognized and align the reporting treatment with accounting teams.
- Review the details meticulously: Verify classification, valuation, country of origin, entry status and IOR information before submitting to avoid delays or rejections during review.
CAPE Filing Errors to Avoid
Based on first-week filing data, the most common issues causing rejections include:
- Outdated ACE credentials: Some ACE accounts may still be connected to former employees or inactive users. A customs broker can file CBP Form 5106 to update the importer’s records before filing.
- Incorrect banking information: The ACE module for receiving refunds is different from the module used to pay duties. CBP may accept the claim but hold payment until banking information is entered correctly.
- Entry number formatting errors: Entry numbers must be 11 alphanumeric characters with no duplicates. For broker and filer accounts, the first three characters must match the filer code on file.
For a complete list of validation errors, see CBP’s IEEPA FAQ.
Looking Ahead
The tariff landscape continues to shift, and the IEEPA refund process may not be the last. Importers that strengthen their compliance processes, data organization and documentation will be better prepared for later CAPE phases and future trade developments.
How Grassi Can Help
Grassi’s Manufacturing & Distribution advisors help importers and businesses with global supply chains navigate the financial and operational impacts of a shifting tariff environment, from strategy and readiness to accounting and cash flow planning. To discuss a specific situation, connect with a Grassi Manufacturing & Distribution advisor today.
To hear the full conversation between Michael Violano and Nunzio Di Filipe, watch the on-demand recording of Grassi’s recent IEEPA tariff refund webinar.
