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CSMS # 68340863 – UPDATE – Consolidated Administration and Processing of Entries (CAPE) for IEEPA Refunds, April 20, 2026, Deployment

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On March 2, 2026, the Court of Appeals for the Federal Circuit (CAFC) issued its formal mandate to the Court of International Trade (CIT) with respect to duties collected pursuant to the International Emergency Economic Powers Act (IEEPA).

• On March 4, 2026, in Atmus Filtration, Inc. v. United States, the CIT ordered “that, with respect to any and all unliquidated entries that were entered subject to the IEEPA duties, U.S. Customs and Border Protection (CBP) is hereby directed to liquidate those entries without regard to the IEEPA duties” and that “[a]ny liquidated entries for which liquidation is not final shall be reliquidated without regard to IEEPA duties.” Atmus Filtration, Inc. v. United States (Ct. No. 26-01259).
• On March 6, 2026, the CIT suspended the immediacy requirement of its March 4, 2026, order to allow CBP to proceed with development of an automated tool capable of processing the unprecedented volume and value of the refunds of duties collected pursuant to IEEPA.
• On April 7, 2026, in Euro-Notions Florida, Inc. v. United States, the CIT ordered that CBP liquidate unliquidated entries that were entered with IEEPA duties without regard to those IEEPA duties, and reliquidate entries for which liquidation is not final without regard to IEEPA duties. The CIT suspended the order to the extent it requires immediate compliance.  

Accordingly, CBP has developed the Consolidated Administration and Processing of Entries (CAPE) automated functionality in the Automated Commercial Environment (ACE) to efficiently process refunds for Importers of Record (IOR) who have paid duties pursuant to the IEEPA. CAPE is a new ACE functionality that will streamline and consolidate refunds and interest payments for entries subject to the IEEPA duties, rather than issuing entry-by-entry refunds. This message provides further details for Phase 1 of CAPE, which is scheduled to deploy 8AM EDT on April 20, 2026. This message also provides additional information on protests, Post Summary Corrections and Automated Clearinghouse payments.

CBP will issue further guidance as additional CAPE functionalities are developed. CBP will maintain all information on IEEPA Refunds and CAPE at the IEEPA Duty Refunds page on CBP.gov.

Guidance

1. CAPE Tab – ACE Portal

IORs and brokers will have the ability to access the CAPE Tab through their ACE Portal account. To file a CAPE Declaration, the IOR or broker will upload a Comma-Separated Values (CSV) file listing up to 9,999 entry numbers on which IEEPA duties have been paid and for which they are requesting an IEEPA duty refund. Only the entry numbers should be included in the CSV file – no other entry-related information is needed.

A separate CAPE Declaration may be submitted for additional entry numbers beyond the first 9,999. The CAPE Declaration may only be submitted by the IOR associated with the entry summaries or by the broker that filed the entry summaries.

The CAPE Declaration template file will be available through the “Upload” button in the CAPE tab of the ACE Portal. 

The CAPE Declaration itself as well as the entry summaries listed will be validated by ACE before the CAPE Declaration is accepted into the ACE Portal and assigned a CAPE claim number. First, the submission undergoes file validations to confirm that:

a. The Declaration contains complete entry numbers that are properly formatted

b. The Submitter is the IOR for the listed entries or the authorized broker that filed the entry summaries on behalf of the IOR

c. The CSV file is not corrupted

If the submission fails any part of the file validation series, ACE will reject the CAPE Declaration. The system will identify, and filers will be able to see, the specific errors that triggered the rejection on the CAPE Tab, allowing filers to identify and correct any errors and resubmit a new CAPE Declaration.

Once the submission passes the file validations, CAPE will run the following entry-specific validations: 

a. Each entry number listed exists in ACE and has at least one Harmonized Tariff Schedule of the United States (HTSUS) Chapter 99 number for IEEPA declared on that entry

b. Not accepted – entry summary flagged for Reconciliation

c. Not accepted – entry type 09 Reconciliation entry

d. Not accepted – entry summary associated with a Drawback entry

e. Not accepted – entry type 47 Drawback entry

f. Not accepted – entry type 08 USMCA Duty Deferral entry

g. Not accepted – entry summary with an Open or Suspended Protest

h. Not accepted – entry summary with “open” or “closed” liquidation status (i.e. Temporary Importation under Bond entry)

i. Not accepted – AD/CVD entry summary in pending liquidation status

· In order to timely apply the liquidation instructions imposed by the Department of Commerce (DOC), an AD/CVD entry with a liquidation status of pending or for which DOC has issued liquidation instructions will not be accepted on a CAPE Declaration.

j. Not accepted – entry summary over 80 days past the liquidation date

k. Not accepted – goods value amount not allowed on IEEPA HTS line.

· The entered value of the imported product reported on the entry summary line should be reported on the Chapter 1-97 HTS classification, unless Chapter 98 reporting provisions require the entered value to be reported differently.

If an entry summary fails any of the entry-specific validations listed above, ACE will remove that individual entry summary from the CAPE Declaration but will continue processing the remaining entry summaries listed. After the system completes the entry-specific validations, ACE will display the results and identify any rejected entries and the reason for their rejection. If the filer corrects the entry-specific errors identified by ACE, it may resubmit the entry summary on a separate CAPE Declaration.

After these file and entry-specific validations are performed and the CAPE Declaration is accepted, in all or part, it is assigned a unique CAPE claim number.

For more information on the CAPE filing process, please see the ACE Portal: CAPE Declarations Quick Reference Guide.

IORs and brokers should ensure they submit a CAPE Declaration for the processing of entries for which IEEPA refunds are due prior to filing a drawback claim. 

IORs and brokers should ensure that they do not submit a CAPE Declaration for entries on which a surety paid IEEPA duties in whole or in part.

2. Mass Processing

Mass processing will be performed on all entry summaries that were accepted on the CAPE Declaration. All applicable IEEPA HTSUS Chapter 99 numbers will be removed at the entry summary line level, creating a new minor version of the entry summary. The duties owed on the entry summary will be recalculated as if IEEPA duties were never owed. The projected refund will be the difference between the duties, taxes, and fees paid on the entry summary and the recalculated duties, taxes, and fees owed on the entry summary. Interest is calculated on these refunds, as it is on any interest eligible refund issued by CBP, in accordance with 19 CFR 24.36.

3. Review and Liquidation/Reliquidation

Once the mass processing is complete, unliquidated entry summaries will be set to liquidate 45 days from the CAPE Declaration acceptance date, except for entries in suspended, extended, or “under review” liquidation status. Entry summaries with extended, suspended, or “under review” liquidation statuses will maintain their liquidation status, and the refund will be issued upon liquidation. 

Warehouse and warehouse withdrawal entry summaries will not be set to liquidate 45 days from the CAPE Declaration acceptance date. Instead, the liquidation process for warehouse entries will continue to be performed by CBP in the normal course after all withdrawals have been made and the warehouse entry is ready for liquidation, at which time CBP will process the refund of the IEEPA duties. 

Liquidated entry summaries will reliquidate the next business day. 

4. Refund

The individual entry summary refunds will be consolidated by IOR or designated 4811 party and liquidation date before they are dispersed in one lump sum. As with all refunds issued by CBP, a check for any unpaid debts to CBP will be made before the issuance of the refund, and the refund amount will equal the difference between the IEEPA duties to be refunded and the unpaid bill(s). 

There may be instances where there is not a one-for-one match of entry summaries submitted on a CAPE declaration versus the entry summaries consolidated on the refund issued to the IOR or 4811 party. These instances occur when entry summaries from different CAPE declarations are on one consolidated refund. Examples of such instances include entry summaries under review, suspended, or extended status prior to the CAPE declaration being accepted; the entry summary is a warehouse or warehouse withdrawal; or the entry summary is selected for review by CBP after the CAPE declaration is accepted. 

ACE Portal users with Importer sub-account access can monitor refund activity using ACE Reports. The new REV-615 CAPE Refunds Trade Report will provide CAPE related refund information.

For unliquidated entries other than warehouse entries and entries with extended, suspended or “under review” liquidation status, importers and authorized brokers may anticipate that valid IEEPA refunds will generally be issued within 60 – 90 days following acceptance of a CAPE Declaration, unless a compliance concern requires further CBP review. This 60-90 day timeframe includes 45 days for CBP review plus additional time to process the refund through Treasury.

Additional Information

Protests

If a protest has been submitted solely for IEEPA refund purposes and the entry summary is within 80 days of the liquidation date, an importer may withdraw the protest and add the entry summary to a CAPE Declaration for faster refund processing. Should the protest be in suspended status, you may reach out to your processing Center to request the suspension be removed. Once removed, the importer can withdraw their protest, then the entry summary can be submitted on a CAPE Declaration.

Post Summary Corrections (PSCs)

Filers are prohibited from initiating an IEEPA duty refund request by filing a PSC. PSCs that are filed due to requesting a refund for entries eligible for duty free treatment due to the lapse of the African Growth and Opportunity Act and the Haiti Hope Help Agreement during October 1, 2025, through February 3, 2026, or any other issue, should be filed prior to submitting a CAPE declaration.

ACH Payments

All refunds from CBP are issued electronically through ACH payments in accordance with the March 25, 2025, Executive Order 14247 “Modernizing Payments to and from America’s Bank Account” and the January 2, 2026, Interim Final Rule 24171 “Electronic Refunds.” To ensure there is no delay in receiving the refund, the IOR or designated 4811 party, must be signed up for ACH refunds. Review ACH Refund sign up guidance here: ACH Refund Enrollment.

To learn more about CAPE functionality in ACE, please see the CAPE Information Notice.

CBP will continue to issue messaging via the Cargo Systems Messaging Service (CSMS) to ensure the trade community is informed and prepared to utilize this new tool and as new enhancements are deployed.

Technical questions regarding this message should be directed to IEEPARefunds@cbp.dhs.gov. General questions regarding this message should be directed to traderelations@cbp.dhs.gov.

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CSMS # 68315804 – Introduction – Consolidated Administration and Processing of Entries (CAPE) for IEEPA Refunds, April 20, 2026 Deployment

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On April 20, 2026, U.S. Customs and Border Protection (CBP) will launch the first phase of the Consolidated Administration and Processing of Entries (CAPE) tool in the Automated Commercial Environment Secure Data Portal (ACE Portal). CAPE will simplify International Emergency Economic Powers Act (IEEPA) duty refund requests made pursuant to court order and in accordance with appropriate statutory authority by providing an electronic pathway to submit valid IEEPA duty refund claims.

CAPE is designed to consolidate refunds of IEEPA duties including interest rather than processing refunds on an entry-by-entry basis. CBP plans to implement CAPE through a phased development approach, adding more functionality in subsequent phases for more complicated scenarios. CAPE Phase 1 is limited to certain unliquidated entries and certain entries within 80 days of liquidation.

Requesting refunds of IEEPA duties requires only the following summarized actions:

• Importers of Record (IORs) and authorized Customs brokers have an established ACE Secure Data Portal account (ACE Portal account)
• Refund recipients use the ACE Portal account to provide CBP with bank account information for refunds
• IORs and authorized Customs brokers submit CAPE Declarations in the ACE Portal

The CAPE process starts with the filing of the CAPE Declaration in the ACE Portal by the IOR or the authorized broker who filed entries on behalf of the IOR. Once accepted, CBP will remove the IEEPA Harmonized Tariff Schedule number and recalculate the duties due without IEEPA, updating the entry to a new version. CBP will review the updated version of the entry and liquidate or reliquidate. Refunds will be consolidated by

IOR or the party designated via CBP Form 4811 and liquidation date.

IORs and brokers who will be filing CAPE Declarations are encouraged to prepare for CAPE filing by ensuring that they have an ACE Portal account and that their bank account information for refunds has been added to their account. For additional information about ACE Portal access and ACH refunds visit the resources below: 

• One Page Overview: ACH Refund Enrollment
• Frequently Asked Questions: ACE Portal and ACH Refunds FAQs
• Training Video: Applying for an ACE Portal Importer Account and Enrolling in ACH Refunds
• Training Guide: ACE Portal Importer Account Application
• Training Guide: ACH Refund Enrollment in the ACE Portal
• Rejected ACH Refund Information: Replacement Refund Instructions

To learn more about CAPE functionality in ACE, please see the CAPE Information Notice. For more information on the CAPE filing process, please see the CAPE Refund Quick Reference Guide.

CBP will continue to issue messaging via the Cargo Systems Messaging Service (CSMS) to ensure the trade community is informed and prepared to utilize this new tool and as new enhancements are deployed.

Technical questions regarding this message should be directed to IEEPARefunds@cbp.dhs.gov. General questions regarding this message should be directed to traderelations@cbp.dhs.gov.

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Please find our newest Space and Equipment report, below.

Please note: regardless of the status showing on the report, please reach out to your BOC Representative to discuss existing status. Space availability changes daily, even multiple times per day. This report is just a general guideline. We will always do everything we can to help you move your freight.

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Please find our newest Space and Equipment report, below.

Please note: regardless of the status showing on the report, please reach out to your BOC Representative to discuss existing status. Space availability changes daily, even multiple times per day. This report is just a general guideline. We will always do everything we can to help you move your freight.

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CIT Expands Paused IEEPA Tariff Refund Order to Include Finally Liquidated Entries

March 30, 2026 by Jacob Kopnick|Top News
Excerpted from TradelawDaily.com

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Court of International Trade Judge Richard Eaton on March 27 broadened his prior order requiring CBP to begin paying refunds of tariffs imposed under the International Emergency Economic Powers Act to include finally liquidated entries. The judge’s initial order only covered non-finally liquidated entries but now states that “[a]ny liquidated entries for which liquidation is final shall be reliquidated without regard to the IEEPA duties.”

However, the judge continued his suspension of the order “to the extent that it requires immediate compliance.”

Eaton amended the order after importers led by AGS Company Automotive Solutions, a key player in the fight for refunds, asked the court to lift the stay in its case to address potential issues stemming from Eaton’s most recent order regarding IEEPA tariff refunds.

Concurrent with his decision to amend his refund order, Eaton then denied AGS’ motion to lift the stay of its case (AGS Company Automotive Solutions v. U.S. Customs and Border Protection, CIT # 25-00255).

In a previous decision in AGS’ case, Judges Gary Katzmann, Timothy Reif and Jane Restani denied the importer’s motion to suspend liquidation of its entries saddled with IEEPA tariffs, since the trade court could order reliquidation of finally liquidated entries in the company’s Section 1581(i) case (see 2512150029).

In their decision, which was issued prior to the Supreme Court finding the IEEPA tariffs to be unlawful, the three judges noted that filing a protest would be futile, since CBP has no role in adjudicating the underlying legality of the IEEPA tariffs. However, in a March 20 order, Eaton said no resolution was reached with the government on how to provide relief for finally liquidated entries.

The judge then said “importers should be aware of the remedies available under 19 U.S.C. § 1514 (Protest against decisions of Customs Service).”

In the wake of this language being published, AGS filed an emergency motion to lift the stay of its case “to be heard on this issue and obtain confirmation” they aren’t required to protest entries CBP liquidates to get IEEPA refunds and, “indeed, that doing so would be futile.”

AGS argued that good cause exists to lift the stay, since the court “has issued seemingly incompatible orders with respect to whether protests are necessary — or even available — to recover duties paid under the unlawful IEEPA tariff regime.” Eaton’s order suggesting importers can protest liquidations of entries with IEEPA duties is “in tension” with the three-judge panel’s order denying AGS’ motion for a preliminary injunction, the brief said.

Importers have relied on the AGS decision, and, in fact, many protest windows have closed. “Without an opportunity to clarify the Atmus Court’s order, Consolidated Plaintiffs risk seeing slip away the paramount legal rights they thought were preserved, to wit, the lack of need to file protests because doing so would be futile, and because of CBP’s promise to issue refunds on liquidated entries,” the brief said.

AGS argued that “[p]otential chaos, steep cost, and inefficiency lie ahead.” If importers start filing protests in response to the court’s order, it’s “more than likely (because they are futile) that CBP will deny those protests,” leading to thousands of new cases at CIT but under Section 1581(a). The court should seek to avoid this outcome, since it’s futile and also “contrary to the very judicial economy and expeditious resolution of refunds this Court has espoused in Atmus,” the brief said.

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Please find our newest Space and Equipment report, below.

Please note: regardless of the status showing on the report, please reach out to your BOC Representative to discuss existing status. Space availability changes daily, even multiple times per day. This report is just a general guideline. We will always do everything we can to help you move your freight.

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Please find our newest Space and Equipment report, below.

Please note: regardless of the status showing on the report, please reach out to your BOC Representative to discuss existing status. Space availability changes daily, even multiple times per day. This report is just a general guideline. We will always do everything we can to help you move your freight.

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Executive Director of US Customs and Border Protection Lays Out CBP’s New System for IEEPA Refunds (CAPE)

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CBP is developing a new capability within its system of record for imported merchandise — the Automated Commercial Environment (ACE) — to prepare to calculate and provide

valid refunds of additional ad valorem duties imposed under IEEPA.

This new ACE functionality is called the Consolidated Administration and Processing of Entries (CAPE). CBP is designing CAPE with four integrated components:

• Claim Portal,
• Mass Processing,
• Review and Liquidation/Reliquidation
• Refund

These components reflect both how CBP anticipates refund requests will proceed through CAPE and how CBP is structuring its development efforts. Each of these components, along with an update on its development, is discussed below.

The CAPE Claim Portal will be web-based and serve as the entry point for importers and brokers to submit IEEPA refund requests (“CAPE Declaration”) to CBP. Once operational, a new tab will be available in both importer and broker ACE Portal accounts.

CBP estimates that the ACE upgrades are already 70% completed.

See full Declaration here: https://storage.courtlistener.com/recap/gov.uscourts.cit.19346/gov.uscourts.cit.19346.39.0_1.pdf

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Major Disruptions Around The Strait of
Hormuz Cause Shipping Issues

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QUOTE:

Iran’s most powerful weapon is not a bomb. It is the geography it controls.

The Strait of Hormuz is a narrow shipping corridor between Iran and Oman. If that passage is effectively closed or significantly restricted for any sustained period, the economic consequences could rival those of a major military escalation.

Markets are already reacting to the possibility. West Texas Intermediate crude oil has soared past $110 per barrel as traders price in rising geopolitical risk. But that move may only represent the early stages of a potential energy shock if tensions escalate further.

The real issue is not simply higher fuel prices. It is the vulnerability of a global energy system that depends heavily on a handful of critical transit routes. (emphasis added)

Excerpted from Forbes.com – https://www.forbes.com/sites/rrapier/2026/03/09/irans-real-nuclear-option-isnt-a-bomb-its-the-strait-of-hormuz/

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Maersk Has 10 Ships Trapped in Gulf, Running Short of Fuel in Asia

Danish containership major A.P. Moller-Maersk has 10 ships trapped in the Persian Gulf and would need at least a week to 10 days to resume normal operations in the event of a cease-fire, CEO Vincent Clerc told The Wall Street Journal.

Brokers say there are more than 100 boxships trapped in the Gulf, with the Jebel Ali port in Dubai a distribution hub for the Middle East.

Some ports in Asia are running low on ship fuel, and oil-supply issues threaten to limit calls by containerships that move everything from cars to electronics and home goods.

“The longer the strait stays closed, the more the replenishing of oil inventories in Asia becomes a challenge,” Clerc said.

If Maersk can’t get fuel in Asia, it will have to charter tankers to bring it in and the extra cost will be reflected in higher freight rates. Daily charter rates for supertankers are at near record levels of more than $400,000.

Excerpted from WSJ.com

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Three ships in Strait of Hormuz hit by ‘unknown projectiles’

Three cargo vessels have been hit by “unknown projectiles” in the Strait of Hormuz, maritime authorities say, as pressure intensifies on one of the world’s most important shipping lanes.

Traffic through the strait – a vital corridor for oil – has fallen sharply since Israel and the US attacked Iran in late February, sending global energy prices soaring.

Iran said it unleashed another volley of retaliatory attacks across the Gulf on Wednesday, with targets including a major oilfield in Saudi Arabia and drones falling near Dubai International Airport.

Earlier, the US said it had “eliminated” 16 ships capable of laying mines in the Strait of Hormuz.

There have been 13 suspected Iranian attacks on vessels operating around the Gulf since the war began.

On Wednesday, Thailand’s navy said it was providing emergency assistance after a Thai-flagged vessel was hit 11 nautical miles north of Oman, causing a fire on board. In a statement, the Royal Thai Navy said the ship’s 23 crew members were being rescued.

Meanwhile, a Japan-flagged container ship sustained minor damage after it was struck 46km (around 25 nautical miles) off the United Arab Emirates coast, maritime security firm Vanguard told the BBC.

And a third cargo vessel was hit 93km (around 50 nautical miles) north-west of Dubai, the UK Maritime Trade Operations (UKMTO) said.

The cause of the attacks are being investigated.

The UKMTO has urged all ships passing through the area to “transit with caution”.

Excerpted from BBC.com

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