What Middle Market Importers Need to Know About the New CBP Tariff Refund Process

CBP’s new electronic tool provides clearer path to IEEPA duty recovery

For middle market businesses that have spent the last two years managing the cost, complexity and uncertainty of tariffs, the refund process is beginning to materialize.

On April 20, 2026, U.S. Customs and Border Protection (CBP) will launch the first phase of its new Consolidated Administration and Processing of Entries (CAPE) tool in the Automated Commercial Environment (ACE) Secure Data Portal. The tool is designed to simplify certain IEEPA duty refund requests by giving importers and authorized customs brokers a way to submit claims electronically.

Why this matters now

For many business owners, tariff updates have been a constant challenge. The possibility of refunds has been a welcome development, but the actual recovery of those costs has seemed far off. You have been asking: if duties are refundable, what does the process actually look like? Who files? What information is needed? How long will it take?

CAPE is the first concrete answer to those questions, at least for importers of record (IOR) who are properly positioned.

The tool is designed to consolidate refunds of IEEPA duties, including interest, rather than process them entry by entry. That should help reduce some of the administrative burden for companies with multiple affected entries.

What CAPE does

At a high level, CAPE creates a digital process for submitting certain valid IEEPA duty refund claims.

Here is a short preview of the process according to CBP:

• The Importer of Record (IOR) or an authorized customs broker submits a CAPE Declaration in the ACE Portal 
• CBP removes the applicable IEEPA Harmonized Tariff Schedule number
• CBP recalculates the duties due without the IEEPA duty
• The entry is updated to a new version for review
• CBP liquidates or reliquidates the entry
• Refunds are then consolidated by IOR, or by the party designated through CBP Form 4811, and by liquidation date

With the consolidation feature, middle-market businesses with large volumes will not be required to go claim-by-claim, saving time and resources.

What CAPE does not do

This rollout is a promising first step, but it does not equal broad relief for every importer and every entry.

Phase 1 is limited and applies only to:

• Certain unliquidated entries
• Certain entries within 80 days of liquidation

More complicated scenarios are expected to be addressed in future phases. So, while CAPE is a step in the right direction, businesses should not assume every refund situation will immediately fit within this first release.

Requirements for seamless CAPE refunds

To request IEEPA duty refunds through CAPE, importers and brokers need to make sure three things are already in place:

1. An ACE Portal account: Importers of Record and authorized brokers must have an established ACE Secure Data Portal account.

2. Refund banking information: Refund recipients must use the ACE Portal account to provide bank account information so CBP can issue electronic refunds.

3. A CAPE Declaration: The IOR or authorized broker must submit the CAPE Declaration through the ACE Portal.

Refund eligibility and refund readiness are not the same. Although it is a simplified electronic refund system, hurdles like incomplete portal access, missing bank information, or unorganized data can significantly hinder the receipt of your refund. Start preparing your ACE account before CAPE Phase 1 begins.

Why middle market companies should pay attention

Middle market businesses may not have extensive customs infrastructure. Responsibilities are often split across finance, operations, procurement, and outside brokers, which can complicate this process further.

The companies best positioned to benefit from CAPE will be the ones that prepare before they need to file. That means confirming access, aligning internal teams, and identifying affected entries early.

Practical steps IOR should take now

• Confirm ACE access
• Align with your customs broker
• Review potentially affected entries
• The bigger picture

CAPE indicates that meaningful steps are being taken toward an effective and structured refund process, but it does not address broader tariff uncertainty or paths to refunds for businesses that are not listed as importers of record.

For those businesses, next steps look a bit different. Without a “direct” path to refunds, they will need to coordinate with IORs and should start today with these steps:

• Identify the importer of record for impacted shipments and determine if they have begun pursuing refunds
• Review invoices and documentation for additional costs and who absorbed them
• Be prepared to substantiate those claims and work collaboratively with IOR to recoup costs
• Review existing contracts for “tariff recovery clauses”

Bottom line

Middle market importers should view the CAPE launch as a reminder to begin planning and preparing to capture refunds.

For IORs

Companies that have their entries organized, their portal access in place, their banking information updated and their internal accountability defined will be in a much stronger position than those scrambling after the fact.

For non-IORs

Without a direct path to refunds, your preparation begins with review. Identify IORs on impacted shipments, communicate proactively with them, and analyze your own records to prepare for ongoing discussions and negotiations.

The refund process is materializing. Those who are ready for it will receive most immediate benefits. For assistance navigating the refund process, fill out the form on this page to connect with our Tariff Advisory specialists.