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Get in touchIEEPA tariff refunds
Understanding the refund steps and how to prepare.
Published on 27 April, 2026
On February 20, 2026, the US Supreme Court ruled that tariffs introduced by the US administration under the International Emergency Economic Powers Act (IEEPA) are unlawful. This decision creates key refund opportunities for importers, and could see the return of several billions of dollars paid in now-invalidated duties.
IEEPA tariff refund mechanism
Launch of the Consolidated Administration and Processing of Entries (CAPE) tool, Phase 1
On 10 April 2026, the US Customs and Border Protection (CBP) announced via the Cargo Systems Messaging Service (CSMS) that the first phase of the Consolidated Administration and Processing of Entries (CAPE) tool will be launched in the Automated Commercial Environment Secure Data Portal (ACE Portal).
CAPE simplifies International Emergency Economic Powers Act (IEEPA) duty refund requests made pursuant to court order and in accordance with appropriate statutory authority. It does so by providing a route to digitally submit valid IEEPA duty refund claims.
In short, CAPE consolidates refunds of IEEPA duties (including interest), as opposed to processing refunds on an entry-by-entry basis. CBP plans to implement CAPE in phases, adding more functionality to the platform at subsequent stages for more complicated scenarios. CAPE Phase 1 is limited to certain unliquidated entries, as well as certain entries within 80 days of liquidation.
To use the new process, importers of record and authorised customs brokers must sign up for an ACE portal account. In addition, refund recipients must provide bank account information through ACE to receive ACH refunds. Importers or their authorised brokers must submit CAPE declarations digitally in the portal. Importantly, CBP encourages trade participants to confirm portal access and refund banking details in advance of the launch date.
According to CBP, the process begins when the importer of record or authorised broker files a CAPE declaration in ACE. Once the declaration is accepted, CBP will remove the relevant IEEPA HTS number, recalculate duties without the IEEPA assessment, and create a new version of the entry for review. CBP will then liquidate or reliquidate the entry as appropriate. Refunds will be grouped by importer of record, or a party designated via CBP Form 4811, and by liquidation date, which should reduce the administrative burden for eligible claims.
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What does this mean for US importers?
For companies that may be eligible for these refunds, the immediate priority is to:
verify ACE Portal access,
confirm Automated Clearing House (ACH) refund enrolment
prepare internal procedures for submitting CAPE Declarations once the tool goes live.
CBP has published supporting reference materials and indicated that additional CSMS messages will follow as new CAPE enhancements are deployed.
How Kuehne+Nagel can help
We can support importers by structuring data, safeguarding rights, and preparing for refund mechanisms.
Please note that detailed line‑level reporting and related analytical support are available as a billable service. Our capabilities include:
Entry population & segmentation: identify all impacted entries, quantify duties paid, and bucket entries by liquidation status and deadlines.
Liquidation monitoring: set up periodic reporting and alerts so liquidation-driven deadlines are not missed.
Protest preparation and filing support: where appropriate, prepare entry lists, assemble supporting documentation, and coordinate timely filings for liquidated entries as a rights-preservation measure.
Refund readiness documentation: create a consolidated refund record (entry schedule/proof of duty payment/supporting documents) that can be submitted quickly if a formal refund process is announced.
Ongoing guidance: as CBP instructions, court orders, or legislation emerge, we will provide practical updates focused on what changes operationally for importers.
ACE portal access support: for importers who need assistance gaining access to the ACE portal, we can assist with the application, initial configuration, training, and support with report writing generation.
Refund estimate snapshot: generate an estimate of your expected refund to better understand your potential return.
Useful links
⚠ Please be aware that this article represents the most current information available from US governmental institutions at the time of publication. This is subject to change.
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