U.S. Customs and Border Protection (CBP) has launched the Consolidated Administration and Processing of Entries (CAPE) tool to help importers and customs brokers claim tariff refunds following a landmark Supreme Court ruling. If your business paid IEEPA tariffs in 2025 or 2026, here is what you need to know to file a refund claim.
Background: Why Tariff Refunds Are Now Available
On Feb. 20, the Supreme Court ruled that President Donald Trump lacked the authority under the 1977 International Emergency Economic Powers Act (IEEPA) to impose the following tariffs:
- 25 percent tariffs on Canadian and Mexican goods
- An additional 10 percent tariff on most imports from China
- Reciprocal tariffs of no less than 10 percent applied to U.S. trading partners
The Court held that while IEEPA grants the President authority to “regulate” imports and exports, it does not extend to imposing taxes. Since the beginning of 2025, the United States collected approximately $240 billion in tariffs—at least half of which were imposed under the IEEPA—making these refund claims potentially significant for affected importers.
What Is the CAPE Tool?
The CAPE tool is CBP’s electronic platform for processing IEEPA duty refund requests. Launched on April 20, as Phase 1 within the Automated Commercial Environment (ACE) Secure Data Portal, the tool provides a streamlined pathway for importers of record (IORs) and authorized customs brokers to submit valid refund claims. Refund processing officially began on May 12.
Step-by-Step: How to File a Tariff Refund Claim
To file an IEEPA duty refund claim through the CAPE tool, follow these three steps:
- Step 1 – Verify your ACE Portal account: IORs and authorized customs brokers must have an active ACE Secure Data Portal account before filing.
- Step 2 – Submit banking information: Refund recipients must provide CBP with current bank account details through the ACE Portal to receive payments.
- Step 3 – File your CAPE Declaration: IORs and authorized customs brokers must submit a CAPE Declaration via the ACE Portal.
How CBP Processes Your Refund
The CAPE process starts with the filing of the CAPE Declaration in the ACE Portal by the IOR or the authorized broker who filed entries on behalf of the IOR. Once accepted, CBP will remove the IEEPA Harmonized Tariff Schedule number and recalculate the duties due without IEEPA, updating the entry to a new version. CBP will review the updated entry and liquidate or reliquidate it. Refunds will be consolidated by IOR or the party designated via CBP Form 4811 and liquidation date.
In short, once your declaration is accepted, CBP will recalculate your original duty liability, update the entry, and issue your refund — consolidated by liquidation date.
Action Steps for Importers and Brokers
To ensure you are positioned to receive your tariff refund as quickly as possible:
- Confirm your ACE Secure Data Portal account is active and in good standing
- Update your bank account information in the ACE Portal
- Identify all entries subject to IEEPA tariffs since early 2025
- Work with your customs broker to prepare and file CAPE Declarations
Next Steps
If your business paid IEEPA tariffs on imports from Canada, Mexico, China, or other trading partners, you may be entitled to a significant refund. The CAPE tool provides a structured, electronic process to recover those duties—but acting promptly is important as refund timelines depend on when declarations are filed.
For more information on filing for tariff refunds, please contact a member of your Zinner & Co. Client Service Team.
