Aldenbridge Customs Brokerage
If you paid IEEPA duties, you may be owed a refund. The window is what matters.
Companies that paid IEEPA duties may be eligible for refunds, but CAPE phases, liquidation dates, and protest windows determine what can still be recovered.
If your company paid duties under the International Emergency Economic Powers Act (IEEPA) over the past two years, money may be owed back to you, but only if your entries are handled within the right window. U.S. Customs and Border Protection (CBP) is now processing those refunds through a new tool called CAPE (Consolidated Administration and Processing of Entries), inside the ACE (Automated Commercial Environment) Secure Data Portal.
The opportunity is real; the risk is letting eligible entries quietly slip past a deadline.
How CAPE works and where it stands
CAPE lets an importer of record or licensed U.S. customs broker file a single declaration covering thousands of entries. CBP recalculates the duties, reliquidates as needed, and issues a consolidated refund, including statutory interest, generally within 60 to 90 days of acceptance unless a compliance concern triggers review.
CBP is rolling it out in phases:
- Phase 1: This phase went live on April 20, 2026. It covers unliquidated entries and those liquidated within 80 days of submission.
- Phase 2: It expands to eligible unliquidated and recently liquidated reconciliation entries.
- Phase 3: While the launch date remains undefined, it is currently targeted by CBP for July 2026. It will cover entries liquidated for more than 80 days. Eligibility is being debated in court and, at the moment, it is limited to importers who have filed a claim against the Court of International Trade (CIT).
Experienced customs experts agree that the entries most at risk are the ones that liquidated quietly in the background. The single most important deadline to track is the protest window: 180 days from the date of liquidation. Filing a protective protest on newly liquidating entries preserves your refund rights, and once that window closes, it generally cannot be reopened.
Recommended steps to manage CAPE eligibility
- Audit your liquidation dates.
- Map each entry to its corresponding CAPE phase.
- Calendar every open protest deadline before it lapses.
Talk to Aldenbridge Customs Brokerage
The importers who recover the most under CAPE act before their windows close, not after. That means knowing which phase each entry falls into, confirming whether refunds with interest are still in play, and filing protective protests before the 180-day clock runs out. It is detailed, entry-by-entry work, and it is exactly what we do.
An experienced IEEPA customs broker maps every entry to its phase and protest deadline before the window closes.
Not sure which CAPE phase applies to your entries, or whether your protest deadlines are still open? Our team reviews these questions every day. Contact Aldenbridge Customs Brokerage at customsentries@aldenbridge.com for an entry review.
This article is for general information and does not constitute legal or tax advice; refund eligibility depends on the specifics of each entry. Sources: U.S. Customs and Border Protection IEEPA Duty Refunds guidance and CSMS notices on the CAPE deployment.
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