[UPDATED: This post has been updated to incorporate CBP’s April 13, 2026 CSMS #68340863] U.S. Customs and Border Protection (“CBP”) issued guidance today explaining importers must utilize the Automated Commercial Environment (“ACE”) portal to request consolidated refunds of tariffs imposed under the International Emergency Economic Powers Act (“IEEPA”) which were found to be illegal by the Supreme Court.

The guidance describes the Consolidated Administration and Processing of Entries (“CAPE”) Declaration functionality within the ACE portal, which allows for the simultaneous processing of multiple entry numbers that were subject to IEEPA tariffs. This functionality enables importers or customs brokers to submit a single declaration in ACE that includes multiple entry numbers, resulting in one consolidated refund amount rather than the processing of individual refunds for each entry. Importantly, as detailed below, all importers must submit a declaration in CAPE to receive eligible refunds regardless of whether an importer has also filed a complaint with the Court of International Trade (CIT).

The CAPE process is being deployed in phases and is currently limited to Phase 1, which covers certain unliquidated entries and certain entries that are no more than 80 days past liquidation. The guidance also outlines the required data elements, submission format, and common errors that trade users should avoid when preparing CAPE Declarations.

 Below are the key features and requirements for submitting refund claims via CAPE. These are outlined in greater detail in CBP’s April 13, 2026 Cargo Systems Messaging Service (CSMS) message.

• Account Eligibility: The CAPE submission is available to Importer, Filer and Organizational Broker accounts with ACE portals.
• How to Submit a CAPE Declaration: The guidance outlines the submission process, including how to download the CAPE upload template from the ACE portal, enter the applicable entry numbers, save the file in the required “CSV (Comma delimited) (*.csv)” format, and complete the required certification and file upload.           
• Navigating Strict System Validations: After submission, the file undergoes an initial format review, followed by a batch validation process in which CBP verifies the claim details against its records. To avoid a “Rejected” status, ensure your entries do not violate these rules:
• No duplicates: The uploaded file cannot contain duplicate entry numbers.
• Account Matching: For Filer and Organizational Broker accounts, the first three characters of the entry number must match your account’s Filer Code. Furthermore, the importer of record (IOR) number on your account must match the IOR of the submitted entry summary.
• Valid Claim Status: The entry summary status must be “Accepted” and the Control Status must be “CBP”. 
  • Excluded Entry Types: CAPE Declarations may not include Duty Deferral (08), Reconciliation (09), Temporary Importation under Bond (“TIB”) (23), or Drawback (47) entries. Entries that are flagged for Reconciliation are also excluded.      

• IEEPA Requirement: Every entry must contain at least one IEEPA HTS code.

If a CAPE Declaration submission encounters issues, the guidance provides instructions identifying the problem and indicating whether corrections are required. How errors are addressed may vary depending on the nature of the issue, and users should consult the CBP’s guidance document to address individual errors and issues.

CBP issued CSMS messages on April 10 and April 13, 2026 addressing these developments. Per the April 13 CSMS, CBP will perform mass processing on all accepted entry summaries, and the duties owed on the entry summary will be recalculated as if IEEPA duties were never owed. Further, interest will be calculated on the refunds in accordance with 19 CFR 24.36.

The April 13 CSMS also details the following:

• Review and Liquidation/Reliquidation: Once the mass processing is complete, unliquidated entry summaries will be set to liquidate 45 days from the CAPE Declaration acceptance date, except for entries in suspended, extended, or “under review” liquidation status.  Entry summaries with extended, suspended, or “under review” liquidation statuses will maintain their liquidation status, and the refund will be issued upon liquidation. 

• Refund Issuance: The individual entry summary refunds will be consolidated by IOR or designated 4811 party and liquidation date before they are dispersed in one lump sum. For unliquidated entries other than warehouse entries and entries with extended, suspended or “under review” liquidation status, importers and authorized brokers may anticipate that valid IEEPA refunds will generally be issued within 60 – 90 days following acceptance of a CAPE Declaration, unless a compliance concern requires further CBP review. ACE Portal users with Importer sub-account access can monitor refund activity using ACE Reports.

• Protests: For entries within 80 days of liquidation, importers who submitted protests solely for IEEPA refund purposes may withdraw the protest and add the entry summary to a CAPE Declaration for faster refund processing.

• Post Summary Corrections (PSCs): Importers 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, and either the IOR or designated 4811 party must be signed up for ACH refunds.

The Husch Blackwell International Trade and Supply Chain team will continue to monitor and provide updates as they become available.  If you have company specific questions or concerns please contact your Husch Blackwell attorney.