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If your company paid IEEPA tariffs between February 2025 and February 2026, a significant cost recovery opportunity is now open — but only if you act.
On April 20, 2026, U.S. Customs and Border Protection launched the CAPE portal — the federal system for submitting IEEPA tariff refund claims. The portal is live now, refunds include statutory interest, and the total amount at stake is approximately $166 billion across more than 330,000 importers. But nothing happens automatically. Every dollar recovered requires an importer to initiate, file, and manage their own claim.
For procurement managers, supply chain leaders, and finance teams, this is not a routine compliance update. It is a potential cost recovery event — one that rewards companies who act quickly and penalizes those who wait.
What Is CAPE and Why Does It Matter?
CAPE stands for Consolidated Administration and Processing of Entries. It is a new electronic system built inside CBP's existing Automated Commercial Environment (ACE) portal — the same platform importers and customs brokers already use for entry filings.
CAPE was created specifically to process refunds of tariffs that were ruled unconstitutional by the Supreme Court on February 20, 2026. In that ruling, the Court held 6-3 that IEEPA does not authorize the president to impose tariffs, invalidating all IEEPA-based duties collected since February 2025.
Rather than processing refunds entry-by-entry — which would be unmanageable at the scale of 53 million shipments — CAPE consolidates all eligible entries into a single declaration filing. Approved refunds include statutory interest calculated from the original entry date, meaning the longer duties sat with CBP, the more interest accrues in your favor.
The key takeaway: CAPE is now live. The refund opportunity is real, it includes interest, and it requires you to file.
Who Can File
Eligibility under CAPE is narrower than many companies expect. Only two parties may submit claims:
Only the importer of record is entitled to receive any approved refund. This distinction matters significantly in practice. Even if tariff costs were passed through in pricing to customers, only the legally recognized importer can file and recover funds.
For companies that rely on third-party importers, distributors, or complex supply chain structures, this determines who controls the refund process — and who ultimately receives the money.
The key takeaway: If you are not the importer of record, you cannot file. Confirm your import structure before investing time in the process.
What Phase 1 Covers — and What It Doesn't
Phase 1 of CAPE, which launched April 20, is intentionally limited to lower-complexity scenarios. Eligible entries include:
Entries excluded from Phase 1 — and potentially addressed in future phases — include entries flagged for reconciliation, entries subject to drawback claims, entries subject to antidumping or countervailing duties pending liquidation, and entries for which liquidation is final and more than 80 days have elapsed.
CBP has indicated that Phase 1 is expected to capture a significant portion of eligible entries. Additional phases planned for later in 2026 will address more complex scenarios. It is not yet clear when those phases will launch.
The key takeaway: If your entries are unliquidated or were liquidated within the past 80 days, act now — Phase 1 is your fastest path to recovery.
A Critical Warning: One Bad Entry Can Sink the Whole Filing
This is the most important operational detail in the entire process, and it is easy to miss.
When you submit a CAPE Declaration, CBP validates both the declaration itself and every individual entry listed in it. If any entry on your declaration doesn't qualify — wrong entry type, already liquidated beyond 80 days, not actually IEEPA-paid, or incorrectly formatted — CBP may reject the entire declaration, not just the problematic line.
This means a single data error across potentially thousands of entries can force a complete resubmission, adding weeks to your timeline.
The key takeaway: Clean, validated data is not just helpful — it is essential. Audit every entry before filing, not after rejection.
Common issues that cause rejections include:
What You Need to Do Before You File
Before submitting a CAPE Declaration, confirm that the following prerequisites are in place:
1. ACE Portal access. The IOR or authorized broker must have an active ACE Portal account with the Importer sub-account enabled. Without this, you cannot access the CAPE tab or submit a declaration.
2. ACH enrollment. All refunds are issued electronically via ACH — no paper checks will be issued. Enroll your bank account information in the ACE Portal before filing. As of April 14, only about 56,500 importers had completed ACH registration out of more than 330,000 who paid IEEPA duties. If you have not enrolled, do it now.
3. Entry compilation. Begin compiling a list of all entries on which IEEPA duties were paid. Each CAPE Declaration can include up to 9,999 entries. Multiple declarations can be submitted if needed.
4. Data validation. Verify that your entries contain IEEPA-related HTSUS Chapter 99 duties and that each entry falls within Phase 1 eligibility parameters before including it in your declaration.
The key takeaway: ACH enrollment is a hard prerequisite for receiving a refund. If it is not set up, approved refunds cannot be paid.
Realistic Timeline: When Will You Actually See the Money?
CBP has stated that approved refunds will generally be issued within 60 to 90 days following acceptance of a CAPE Declaration. However, that clock does not start at submission — it starts at acceptance, which itself can take two to four weeks during the initial filing surge as CBP processes the volume of incoming declarations.
For importers filing a clean, accurate declaration in late April 2026, a realistic expectation is receiving funds via ACH somewhere between mid-July and mid-August 2026.
Entries that are extended, suspended, or under compliance review will maintain their liquidation status, with refunds issued upon eventual liquidation — which may extend beyond that window.
The key takeaway: Filing early matters. Every week of delay in submitting a clean declaration pushes your refund timeline back by a week.
The Broader Legal Picture
The refund opportunity exists because of ongoing and settled legal developments — but the landscape is not entirely static.
The Supreme Court's February 20, 2026 ruling in Learning Resources, Inc. v. Trump settled the core question: IEEPA cannot be used to impose tariffs. The Court of International Trade subsequently ordered CBP to begin processing refunds, leading to the CAPE system.
However, questions remain about entries with final liquidation status, the scope of future CAPE phases, and how disputes or denied claims will be resolved. Companies should plan for some variability in both timing and outcomes, particularly for entries that fall outside Phase 1 eligibility.
The key takeaway: The legal foundation for refunds is settled — but execution, eligibility boundaries, and future phases remain in development.
An Alternative: Selling Your Refund Claims
Given the complexity and timeline involved, some companies are exploring an alternative: selling their tariff refund claims to third-party financial firms.
In this model, the importer receives an immediate lump-sum payment at a discount. The buyer assumes the administrative burden and risk and retains any eventual refund proceeds.
This approach may appeal to companies that need immediate liquidity, prefer certainty over potential upside, or lack internal capacity to manage the claims process.
However, the tradeoff is reduced total recovery — and the assignment of customs claims involves legal complexities that vary by situation. Consult legal counsel before pursuing this route.
The key takeaway: Selling claims offers faster cash at a discounted value. It is a legitimate option but should not be pursued without legal guidance.
What This Means for Sourcing Strategy
This situation reflects a broader shift in how tariffs must be managed. They are no longer a fixed cost to be absorbed — they are a dynamic variable that can change, be challenged, and in some cases, be recovered.
For procurement and supply chain teams, the practical implications are:
Companies that built clean import data practices during the IEEPA period are the ones filing clean CAPE declarations today. Companies that didn't are spending those same weeks reconciling records instead of recovering funds.
The key takeaway: Clean data and a deliberate import structure are competitive advantages — not just compliance requirements.
How 889 Global Solutions Fits In
Founded in 2000, 889 Global Solutions is a certified MBE/WBE contract manufacturing and sourcing partner with a global factory network across China, India, Vietnam, and Taiwan. Partner facilities are ISO 9001 and ISO 13485 certified, supporting both industrial and medical applications across three core areas: medical device sourcing, industrial manufacturing, and chemical products including molecular sieves.
A key differentiator is that 889 acts as the FDA-registered initial U.S. importer — taking legal ownership of goods on behalf of clients and managing the import process domestically. In the context of the CAPE refund process, this matters: when 889 holds importer-of-record status, clients transact with a domestic entity and the complexity of international import compliance — including processes like CAPE — is managed on their behalf.
With documented client savings of 20–50%, the focus is not just on cost reduction — it is on building resilient, compliant supply chains that can adapt when regulatory changes create both risk and opportunity.
The key takeaway: The right import structure improves compliance control and positions your company to act quickly when regulatory changes have financial implications.
Key Takeaways
Ready to talk about your sourcing situation? Contact 889 Global Solutions for a sourcing review at www.889globalsolutions.com/contact
This post is for general informational purposes only and does not constitute legal or trade compliance advice. For guidance specific to your business, consult a licensed customs attorney or trade compliance professional.
