CBP Announces April 20, 2026 Launch of CAPE Refund System for Import Duties

Heusel, Mark Wang, Hezi Clark, Jacob L.
April 2026
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Following Dickinson Wright Trade Team’s latest update on CBP’s development of the Consolidated Administration and Processing of Entries (“CAPE”) system for IEEPA duty refunds , several notable developments have occurred.

First, Atmus Filtration, Inc. v. United States has been voluntarily dismissed by the plaintiff. Euro-Notions Florida, Inc. v. United States now serves as the lead case moving forward with respect to IEEPA tariff refunds. On April 7, 2026, the U.S. Court of International Trade (“CIT”) in Euro-Notions followed the Atmus case in declaring the CIT’s ability to issue a nation-wide order, affirming the US Supreme Court decision that IEEPA tariffs are unconstitutional, and ordering CBP to issue IEEPA duty refunds to unliquidated entries, entries where liquidation is not yet final, and entries where liquidation is final.

In addition, CBP issued further guidance on April 10 and April 13, 2026, regarding the deployment and operation of CAPE. Most importantly, CBP confirmed that CAPE Phase 1 will go live on April 20, 2026, at 8:00 AM EDT, at which time importers may begin submitting CAPE Declarations. A summary of CBP’s guidance follows below, including key details on eligibility, filing procedures, and processing timelines for CAPE Phase 1.

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

CSMS #68315804 issued on April 10, 2026 provides with the most clarity on the actual CAPE Declaration, when it will begin, and filing process. Below is a brief overview of what was provided:

CAPE system will go live on April 20. That means an importer can start submitting a CAPE Declaration on that date.
CBP forwarded a “Trade User Information Notice” that provides a more detailed summary of the CAPE system.
CAPE Declaration filing instructions. CBP also provided a step-by-step guide with screenshots on how to submit a CAPE Declaration through ACE.

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

CSMS #68340863 issued on April 13, 2026 provides further clarifications and details on CAPE and its deployment.

Phase 1 of CAPE is scheduled to deploy 8AM EDT on April 20, 2026.
Only the entry numbers should be included in the CAPE Declaration, which should be saved and submitted as a CSV file.
The CAPE Declaration may only be submitted by the IOR associated with the entry summaries or by the broker that filed the entry summaries.
Additional clarification on Protests, PSCs, and ACH Payments

Protest

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.
If the protest is in suspended status, an importer 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.

PSCs

Filers are prohibited from initiating an IEEPA duty refund request by filing a PSC.

ACH Payments

All refunds from CBP are issued electronically through ACH payments

CBP’s recent guidance provides the clearest framework to date for implementation of the CAPE system and confirms that importers may begin submitting refund requests as early as April 20, 2026 for qualifying entries. At the same time, CAPE Phase 1 remains limited in scope, with additional development expected to address entries for which liquidation is final. Importers should continue to monitor developments closely, particularly with respect to future phases of CAPE. In the interim, importers may wish to prioritize identifying eligible entries, confirming ACE data accuracy, monitoring liquidation dates and other deadlines for entries, and preparing CAPE-ready submission files to facilitate timely refund claims.

Separately, CBP submitted a new declaration on April 14, 2026 in Euro-Notions, confirming that primary development of all CAPE Phase 1 components has been completed. CBP also reiterated that refunds will be issued electronically. Finally, CBP confirmed that pre-liquidation refunds for suspended entries subject to AD/CVD will be processed manually. On April 15, 2026, the Court issued an order in the Euro-Notions case finding that CBP remains on track to launch CAPE Phase 1 on April 20, 2026, and highlighted that refunds issued through CAPE may be subject to offset against other outstanding duties. Importantly, the Court found that CAPE Phase 1 and IEEPA refunds are eligible for all importers and are not limited to only those who filed complaints in the CIT.

We will continue to monitor updates from CBP and provide further guidance as it becomes available.

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