IEEPA Tariff Refunds Start April 20, 2026: Six Steps Every Importer Must Take Now

If your business has been paying tariffs under the International Emergency Economic Powers Act (IEEPA), significant relief may be on the way. In response to lawsuits filed at the U.S. Court of International Trade (CIT), U.S. Customs and Border Protection (CBP) has announced it will begin processing IEEPA duty refunds starting April 20, 2026, and with interest.

At Abady Law Firm, we have been closely monitoring this litigation on behalf of our clients and the broader trade community. This post covers everything you need to know about the new refund process, who qualifies, and the concrete steps you should be taking right now.

What Is the CAPE Refund System?

To manage the volume of refund requests, CBP is rolling out a new platform called CAPE (Consolidated Administration and Processing of Entries). Rather than processing refunds on an individual entry-by-entry basis, CAPE batches IEEPA duty refunds, including accrued interest, through CBP’s existing ACE (Automated Commercial Environment) Secure Data Portal.

Who Qualifies for Phase 1 Refunds?

CBP is implementing CAPE in phases. Phase 1, launching April 20, is limited to:

• Certain unliquidated entries
• Liquidated entries within 80 days of their liquidation date

Entries that fall outside this window will need to wait for future phases. CBP has confirmed that additional phases are being developed to address more complex refund scenarios, but timelines for those phases have not yet been announced.

How the CAPE Refund Process Works: Step by Step

Per CBP CSMS #68315804 (updated CSMS #68340863), the following process applies to all CAPE refund requests:

1. The Importer of Record (IOR) or customs broker submits a CAPE Declaration through the ACE Portal by uploading a .CSV file listing all entry numbers for which an IEEPA duty refund is being requested.
2. CBP removes the IEEPA HTS number from the entry, recalculates duties owed, and generates an updated version of the entry.
3. CBP reviews the updated entry and proceeds to liquidate or reliquidate it accordingly.
4. Refunds are consolidated by IOR (or by a designated party via CBP Form 4811) and issued by liquidation date.

Note: IORs and customs brokers who file CAPE Declarations must have an active ACE Portal account with their U.S. bank account information on file to receive refunds via ACH.

Your IEEPA Refund Action Checklist: Do These Now

Time is critical. Here is what every importer, customs broker, and trade business should do immediately to preserve eligibility and protect their refund:

• ✅ File a lawsuit at the U.S. Court of International Trade. While current CIT orders appear to benefit both litigants and non-litigants, this position is expected to be appealed. Resolution could take months. Filing now secures your legal standing regardless of the outcome.
• ✅ Create an ACE Portal account immediately if you do not already have one. No account means no refund. This is non-negotiable.
• ✅ Reactivate your ACE account if you have not logged in within the past 45 days. Inactive accounts must be restored by calling ACE Support directly. Do not wait until April 20 to discover your account is locked.
• ✅ Register for ACH payments by linking your U.S. bank account within the ACE Portal. This is how your refund will be disbursed.
• ✅ Generate an ACE report covering all entries on which IEEPA duties were paid, including liquidation dates. Abady Law Firm can assist you in pulling and reviewing this report.
• ✅ Prepare your Phase 1 CAPE Declaration: a .CSV file containing entry numbers only for entries (1) on which IEEPA duties were paid and (2) that are unliquidated or liquidated within 80 days of submission. We can help you prepare this filing accurately.

Additional Resources from CBP

CBP has published detailed guidance, FAQs, and a CAPE Declarations Quick Reference Guide on its website. Bookmark this page as it will be updated throughout the phased rollout:

🔗 CBP Official IEEPA Duty Refunds Page

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A Note on the Potential for Appeal

We want to be transparent: the government has remained silent on whether it intends to appeal the CIT’s ruling. If an appeal is filed, the current refund framework could face interruption or reversal. We are monitoring this closely and will issue an update the moment there is anything to report.

This uncertainty is precisely why we recommend that importers take protective legal steps now rather than waiting for the situation to fully resolve.