Refunding Duties Collected under the International Emergency Economic Powers Act (IEEPA)

U.S. Customs and Border Protection (CBP) has announced a new automated process to manage refunds of duties collected under the International Emergency Economic Powers Act (IEEPA). Due to the high volume of refund requests, CBP will issue refunds in phases, using a new tool within its Automated Commercial Environment (ACE).

CBP is launching a new refund processing tool called Consolidated Administration and Processing of Entries (CAPE):

  • Starting April 20, 2026, importers of record or the licensed customs broker who filed the entry may submit requests for eligible IEEPA duty refunds through CAPE.
  • Refund requests must be submitted through the ACE Portal using a CAPE Declaration.

During Phase 1, CBP will accept CAPE Declarations for certain unliquidated entries and certain liquidated entries up to 80 days past their liquidation date. Entries with a liquidation status of suspended, extended, or under review may also be included. These entries will maintain their current status, with any validated refund issued at liquidation.

Once a CAPE Declaration is accepted, valid IEEPA refunds are generally expected to be issued within 60–90 days, unless additional compliance review is required. CAPE will consolidate refunds by liquidation (or reliquidation) date and importer of record (or a designee identified on a CBP Form 4811). Once processed, refunds will be issued electronically via Automated Clearing House (ACH) in accordance with applicable laws and any relevant court orders.

Importers are encouraged to prepare by confirming access to the ACE Portal, the Importer sub‑account, and completed ACH refund banking details, which are required before refunds can be issued. Importers and brokers may also begin compiling lists of entries where IEEPA duties were paid to support future CAPE submissions.

Key submission details

  • A single CAPE Declaration may include up to 9,999 entries.
  • Brokers may include entries filed for multiple importers in one submission.
  • Once a CAPE Declaration is accepted, it cannot be amended.
  • If additional eligible entries are identified later, a new CAPE Declaration must be submitted.
  • Each entry may only be included once across all CAPE Declarations.

CBP has advised that additional entry types may be supported in future phases of CAPE, including reconciliation entries, drawback‑related entries, entries under protest, entries not filed in ACE, AD/CVD‑related entries pending liquidation, and entries for which liquidation is final. CBP will issue further guidance as these capabilities are developed.

How Maersk can support you

Maersk Customs Services is closely monitoring developments and as additional guidance becomes available, we will continue to provide updates. Our team is available to support customers with:

  • Entry analysis and identification of potentially affected transactions
  • Monitoring liquidation status and protest timelines
  • Evaluating potential tariff refund exposure
  • Preparing for the ACE refund submission process

Customers with questions regarding specific shipments, entries, or tariff exposure are encouraged to contact their local Maersk Customs Service team. Within the next week, Maersk will be hosting an educational customer webinar to cover more details around this process with registration being released soon to our customers.

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