IEEPA duty refunds are filed through CBP’s CAPE process in the ACE Secure Data Portal, not through a normal ABI entry transmission. The importer of record or its authorized customs broker submits a CSV list of affected entries. CBP says valid refunds are generally issued within 60-90 days after CAPE Declaration acceptance unless a compliance issue or liquidation status requires more review.
CBP’s IEEPA refund process is now an operational customs project, not just a legal headline. Importers have to identify the affected entries, confirm who is allowed to file, set up ACE and ACH refund details, and avoid filing a CAPE Declaration before the underlying entries are clean.
That matters because a CAPE Declaration can touch many entries at once. CBP’s public guidance says each declaration can include up to 9,999 entries, and accepted declarations cause ACE to remove the IEEPA Chapter 99 lines and corresponding duties before liquidation or reliquidation.
What CAPE is doing
CAPE stands for Consolidated Administration and Processing of Entries. CBP built it to process IEEPA refund requests in batches, rather than one entry at a time.
| Step | What happens | Importer risk |
|---|---|---|
| 1. Entry inventory | The importer or broker identifies entries with IEEPA duty lines. | Missing entries means missed refunds; bad entry numbers can reject the upload. |
| 2. CAPE Declaration | A CSV entry list is uploaded in the ACE Secure Data Portal. | Only the IOR or authorized customs broker can file for the relevant entries. |
| 3. CBP validation | CBP validates the declaration and returns an accepted status and claim number. | Compliance concerns, suspended entries, warehouse entries, or corrections can delay payment. |
| 4. Liquidation / reliquidation | ACE removes IEEPA Chapter 99 lines and recalculates duties. | Over- and under-payments are netted at the entry level under normal liquidation rules. |
| 5. Refund issuance | Refunds are consolidated by IOR or Form 4811 notify party and liquidation date. | ACH setup and refund-recipient information have to be correct before the money can move. |
Who can file
CBP says the filer must be the importer of record or the authorized customs broker that filed the entries on behalf of that importer. The filer needs an established ACE Secure Data Portal account, and CBP has fraud controls tied to ACE access and entry association.
That makes the broker file important. Before filing, importers should confirm:
- which broker filed the original entries;
- whether the broker is authorized to file CAPE Declarations;
- whether ACE and ACH refund setup is complete;
- whether a CBP Form 4811 notify party is in place for refund routing;
- whether any affected entries also need PSCs, protests, drawback handling, or reconciliation review.
What to prepare before filing
CBP’s CAPE process is entry-list driven. The core upload is a CSV file listing the entries for which IEEPA refunds are requested, and CBP does not require other data fields in that file. That simplicity is useful, but it also means the importer’s pre-filing review has to happen before upload.
Use the IEEPA refund claim readiness checklist to sort entries by liquidation status, broker authority, ACE access, ACH setup, Form 4811 routing, PSC/protest risk, drawback status, and warehouse/suspended-entry status before filing.
- Build an entry inventory. Pull every entry summary that includes an IEEPA Chapter 99 line and sort by importer, filer, entry date, liquidation status, and payment amount.
- Preserve leading zeroes. CBP’s FAQ says entry summary numbers beginning with zero may need an apostrophe in the CSV so spreadsheet software does not strip the zero.
- Clean unrelated corrections first. If an entry needs a post summary correction for a non-IEEPA issue, handle that before the CAPE Declaration wherever possible.
- Separate special cases. Warehouse entries, suspended entries, AD/CVD entries, reconciliation entries, drawback-designated entries, and entries under review can follow different timing.
- Confirm refund recipient setup. Refunds are electronic. ACE refund and ACH details should be live before a claim is accepted.
How long refunds take
CBP says valid IEEPA refunds are generally issued within 60-90 days after CAPE Declaration acceptance, unless a compliance concern requires further review. Entries that are extended, suspended, under review, or in warehouse status can maintain their liquidation status and receive validated refunds at liquidation.
Importers should not treat “accepted” as the same thing as “paid.” Acceptance gives the filer a status and claim number. Payment still depends on liquidation/reliquidation, refund routing, possible netting, and whether CBP identifies any compliance concern.
How to track refund status
CBP says importers and brokers can use ACE Reports to monitor activity. The relevant report names in CBP’s guidance include:
- REV-603 Trade Refund report for pending and successful refunds;
- REV-613 ACH Rejected Refunds report for refunds rejected because the recipient is not enrolled in ACE Refunds;
- REV-615 Trade CAPE Detail Refund Report for CAPE-specific refunds once refunds are issued.
When to talk to counsel before filing
A broker can help assemble the entry inventory and file eligible CAPE Declarations. But importers should involve trade counsel if the claim touches litigation strategy, finally liquidated entries outside the current CAPE scope, protest preservation, contractual refund ownership, or a disputed compliance position.
The practical rule: do not use the refund process to rush past an entry problem. If the classification, valuation, origin, or refund recipient is wrong, fix the file before asking CBP to process the refund.
Need to file or audit IEEPA refunds?
Greenwich Mercantile can review your affected entry list, identify which entries are ready for CAPE, coordinate with the filer, and flag entries that need correction before submission.
- IEEPA entry inventory and liquidation-status review
- ACE / broker / Form 4811 readiness check
- CAPE filing coordination and refund-status tracking
Sources
This guide summarizes CBP materials available as of June 27, 2026. Primary sources: CBP IEEPA Duty Refunds, CBP Fact Sheet: IEEPA Duty Refunds, CBP Trade Information Notice: CAPE, and CBP webinar overview.