CAPE Denials Show Tariff Refunds Are Not Automatic: What Importers Should Do Now

Refund process begins, but early denials signal a tougher path

The tariff refund process is underway, but early evidence has shown that the process is not exactly seamless.

U.S. Customs and Border Protection’s new Consolidated Administration and Processing of Entries (CAPE) tool is now active in the ACE Portal, enabling importers and authorized customs brokers to submit certain IEEPA duty refund claims electronically. CBP activated the first phase of CAPE on April 20, 2026, and the tool is designed to consolidate refunds of IEEPA duties, including interest, rather than process refunds entry by entry.

According to recent reporting on court filings and CBP data, roughly 15% of entries that cleared initial review were denied for failing entry-specific validations as of April 26. The first tariff refund payment is expected around May 11. Currently, approximately 21% of applicable IEEPA tariff entries have been accepted, and about 3% are in the refund stage.

For middle market importers, refund eligibility does not equal refund readiness.

Talk to UHY about a CAPE refund readiness review

Why CAPE refund requests are being denied

Based on our tariff team’s analysis, early denials appear to fall into three practical categories: data formatting issues, file corruption, and identity mismatches.

1. Data formatting issues

Importers should confirm that the file is uploaded in .csv format and that the file contains only the required data.

For this process, the only data included in the file should be the 11-digit entry number.

Any additional columns, formulas, formatting, notes, or changes to the template can create avoidable issues. This is not a general spreadsheet, and it should be treated as a structured submission file.

2. File corruption

Some denials may be caused by technical issues with the file itself.

This should be avoidable if the importer of record downloads and uses the CAPE template directly from the ACE system. Issues may arise when files are edited across multiple systems, converted repeatedly, saved in the wrong format, or uploaded after template fields have been altered.

Before submitting, importers should confirm that the file opens cleanly, remains in the required .csv format, and has not been corrupted during preparation or transfer.

3. Identity mismatches

The submitter must be the listed importer of record or the specific customs broker that originally filed the entry summaries on that importer’s behalf. If the wrong entity submits the claim, or if CBP records do not align with the party seeking the refund, the claim may fail validation.

Importers should also verify that the correct email address and banking information are on file. If importer identity information needs to be corrected, businesses may need to submit CBP Form 5106, either directly to CBP or electronically through their customs broker.

Don’t let a filing error delay your eligible refund

A rejected CAPE submission may be fixable, but it can still slow down cash recovery and create unnecessary administrative work. UHY’s Tariff Advisory team can help importers review CAPE readiness, identify filing issues, validate entry data and coordinate with customs brokers before submissions are delayed or denied.

What importers should do now

Importers should treat the early CAPE denial rate as a prompt to review their documentation and process before filing or refiling.

A practical review should include the following steps:

• Confirm the filer: Make sure the CAPE Declaration is submitted by the importer of record or the authorized broker that filed the original entry summaries. If a third party is managing customs activity, confirm who is listed as the importer of record for each affected entry.
• Validate entry data: Review the entries being submitted and confirm that the 11-digit entry numbers are accurate. Avoid submitting incomplete, duplicate, or incorrectly formatted data.
• Use the ACE template directly: Download the CAPE template directly from ACE rather than reusing an altered file. This reduces the risk of formatting or corruption issues.
• Keep the file clean: Upload the file in .csv format and include only the required 11-digit entry numbers. Remove extra columns, headers, formulas, hidden tabs, notes, or other non-required information.
• Verify banking information: Confirm that ACH refund banking information is accurate and current. Inaccurate or outdated banking information can slow the refund process or create additional follow-up.
• Check importer account information: Review the importer profile in ACE, including email and identity information. If information is outdated or does not match CBP records, work with CBP or the customs broker to correct it.
• Track denials and resubmissions: Create an internal log of denied entries, rejection reasons, corrective actions, and resubmission dates. This will help finance, tax, customs, and operations teams stay aligned.

What non-importers of record should do

Non-IOR businesses may not have a direct path to refunds through CAPE and should instead coordinate with the importer of record. These companies should identify the IOR for impacted shipments, review invoices and documentation, determine who ultimately bore the duty cost and review contracts for tariff recovery language.

For non-IORs, the action item is not simply “file through CAPE.” It is to determine whether a refund opportunity exists, who has legal standing to pursue it and whether commercial agreements allow the refund benefit to flow back to the business that absorbed the tariff cost.

What the 15% denial rate means for importers

A denial does not necessarily mean an importer has lost the opportunity to recover eligible duties. Importers will be able to correct errors and resubmit, which means the immediate risk is delayed refunds.

For companies managing tariff-driven cost pressure, cash flow constraints, supply chain volatility or customer pricing decisions, a delayed refund can create real operational consequences.

CAPE was intended to create a more efficient path for valid IEEPA duty refunds, but the system still depends on the quality of the information submitted. CBP’s Phase 1 rollout is limited to certain unliquidated entries and certain entries within 80 days of liquidation, meaning not every refund scenario is covered in this initial phase.

Why this matters for middle market companies

Middle market businesses often have tariff data spread across procurement, finance, logistics, tax and outside brokers. That makes CAPE readiness more than a customs issue.

A company may know it paid tariff-related costs but still struggle to answer basic refund questions quickly:

• Who was the importer of record?
• Which broker filed the entry summaries?
• Which entries are eligible under CAPE Phase 1?
• Is the ACE account active and accurate?
• Is ACH refund banking information current?
• Does the submission file meet CBP’s format requirements?

The companies best positioned to recover funds quickly will be those that can answer these questions before submitting.

What to watch next

The next major milestone is the first expected refund payment around May 11, followed by additional court activity related to the refund process.

Importers should also continue monitoring CBP guidance, CAPE updates, and future phases of the refund process. Phase 1 does not resolve every refund scenario, and more complex cases may require additional guidance or later functionality.

Bottom line

CAPE is a meaningful step forward, but early denial activity shows that tariff refunds were not without effort.

For importers of record, now is the time to review ACE access, confirm banking information, validate entry numbers and coordinate closely with customs brokers. For non-IORs, the priority is to identify the importer of record and begin documenting any indirect refund recovery position.

The 15% denial rate is a good reminder to document and prepare accordingly to avoid delays.

Need help protecting your tariff refund opportunity?

CAPE denials can create delays, but many issues are preventable with the right review process. UHY’s Tariff Advisory specialists can help importers assess eligibility, review denied entries, validate CAPE submission files, confirm importer-of-record details, and coordinate next steps with customs brokers.

Contact UHY’s Tariff Advisory team to review your CAPE refund position and reduce the risk of avoidable delays.