$166 Billion in Tariff Refunds Begin Today: CBP’s CAPE Portal Goes Live

WASHINGTON — At 8:00 a.m. Eastern Time on Monday, U.S. Customs and Border Protection quietly opened a web page that, over the coming year, is expected to return as much as $166 billion to American companies. It is, by dollar value, one of the largest government refund programs in modern memory — and it began with the click of a button.

The portal, known by the acronym CAPE — for Consolidated Administration and Processing of Entries — lives inside the Automated Commercial Environment, or ACE, the same secure system customs brokers already use to file daily import entries. Starting today, importers of record and their licensed brokers can begin uploading claims to recover duties paid under the International Emergency Economic Powers Act (IEEPA), a category of tariffs the U.S. Supreme Court struck down on February 20 in a 6–3 decision.

In a written guidance document posted to its website, CBP described the purpose of the new system in plain terms: CAPE will simplify International Emergency Economic Powers Act (IEEPA) duty refund requests made pursuant to court order and in accordance with appropriate statutory authority by providing an electronic pathway to submit valid IEEPA duty refund claims.¹

The simplicity, trade attorneys say, is only skin-deep.

The scale: 330,000 importers, 53 million shipments

The scope of what CBP is being asked to unwind is, in federal terms, enormous. According to court filings cited by the Associated Press, over 330,000 importers paid a total of about $166 billion on over 53 million shipments under the IEEPA tariffs.² By comparison, the entire 2023 federal tax refund season moved roughly $300 billion — but it ran through an agency (the IRS) that has spent decades processing individual claims. Customs and Border Protection has never done anything remotely like this.

In a declaration filed with the U.S. Court of International Trade in March, the agency itself estimated that processing the refund volume under its traditional, entry-by-entry procedures would have required 4,431,161 working hours — the equivalent of 533,896 eight-hour workdays if completed sequentially.³ That figure, which CBP used to justify its 45-day extension request, is why CAPE exists at all: without a mass-processing tool, the refund queue would have stretched into the 2030s.

As of April 14, according to CBP, 56,497 importers had completed registration and were eligible for refunds totaling $127 billion, including interest.⁴ That leaves hundreds of thousands of other businesses that have not yet registered for electronic refunds — and will not be paid until they do.

If your company paid IEEPA tariffs on imports between March 2025 and February 2026 and has not yet set up an ACE Portal account with ACH refund enrollment, you are not in line yet. You are behind the line.

What Phase 1 covers — and, more importantly, what it does not

The launch today is deliberately narrow. CBP has signaled it will expand the CAPE system in later phases, but the first phase is limited in two specific ways. Per the agency’s own Trade Information Notice, Phase 1 is limited to certain unliquidated entries and certain entries within 80 days of liquidation.¹

In customs terminology, “unliquidated” means the entry has been filed and an estimated duty paid, but CBP has not yet finalized the amount. An entry typically liquidates 314 days after filing, which means the vast majority of imports filed in the back half of 2025 are still in this status — and therefore in scope for today’s launch. According to the global trade firm Flexport, the first phase will account for an estimated 63% of IEEPA tariffs.⁵

The other 37% — entries that liquidated more than 80 days ago — will have to wait for Phase 2, for which CBP has not yet set a date. Industry analysts at the law firm Norton Rose Fulbright wrote that we anticipate the processing of those claims will take longer than those during the first phase.⁶ Importers with older entries have two options in the meantime: file a formal protest with CBP if they are still inside the 180-day protest window, or pursue their claim through the Court of International Trade.

Certain entries are explicitly excluded from Phase 1 entirely, including:

• Entries tied to a drawback claim (including Type 47 Drawback entries)
• Entries subject to antidumping or countervailing duties pending liquidation under 19 U.S.C. § 1504(d)
• Entries for which liquidation is final or more than 80 days have elapsed
• Duty Deferral (Type 08) and Temporary Importation under Bond (Type 23) entries

The law firm Troutman Pepper Locke, in a briefing published last week, cautioned clients that post summary corrections (PSCs) may not be used to initiate IEEPA refund claims, making CAPE the exclusive mechanism for requesting these refunds for covered entries.⁷

The math of $166 billion — and the interest clock ticking underneath it

The headline figure of $166 billion is only part of the story. Under federal law, CBP owes interest on overpaid duties from the date the importer deposited the estimated duty until the date of refund. Under 19 U.S.C. § 1505(c), that interest accrues continuously.

The U.S. Chamber of Commerce, in its guidance for small businesses, notes that the interest rate is 6% at present and that the Court of International Trade has observed interest is accumulating every day, with approximately $650 million accruing per month.⁸

A separate analysis from the Cato Institute, cited by CBS News, put the accumulating interest cost even higher: the delay in refunding companies for emergency tariffs invalidated by the high court is costing U.S. importers a total of $700 million per month, or $23 million per day.⁹ If refunds stretch a full year, Cato estimated, taxpayers could owe an additional $8.4 billion in interest on top of the principal.

Penn Wharton’s Budget Model projected a range even wider than CBP’s own estimate, writing in a February 20 analysis that reversing the IEEPA tariffs will generate up to $175 billion in refunds.¹⁰

Whether the final cost to the Treasury lands at $130 billion, $166 billion, or $175 billion, every importer who has paid an IEEPA duty in the last 13 months has a financial interest in moving quickly.

What actually happens when you file

Here is the mechanical flow, as CBP describes it in its official Phase 1 guidance document:

1. The importer of record, or an authorized broker, logs into the ACE Portal and opens the new CAPE tab.
2. The filer downloads a CSV template, populates it with entry numbers on which IEEPA duties were paid (up to 9,999 entries per declaration), and uploads it.
3. ACE runs two rounds of automated validations — one on the file itself, a second on each individual entry.
4. Accepted declarations are assigned a CAPE claim number; entries that fail validation are rejected line by line, with reasons shown to the filer.
5. ACE then removes the IEEPA Chapter 99 Harmonized Tariff Schedule codes from each accepted entry, recalculates the duty owed, and reliquidates or liquidates the entry as appropriate.
6. The refund — consolidated by importer and by liquidation date — is issued electronically via ACH to the bank account on file.

CBP told trade filers that importers and authorized brokers should anticipate that valid IEEPA refunds will generally be issued within 60 - 90 days following acceptance of the CAPE Declaration, unless a compliance concern requires further CBP review.¹ In industry forums this morning, some brokers predicted that clean, well-documented filings could pay out as quickly as 45 days.

A critical caveat: once a CAPE Declaration is filed and accepted, it cannot be amended. Errors have to be fixed by submitting a new declaration with the corrected entries. Entries can only appear on one accepted declaration at a time; duplicates are automatically rejected.

Trade attorneys warn: the easy part is the intake

Several of the trade lawyers and customs specialists interviewed over the past week used the same word to describe the mood: “composure.”

Meghann Supino, a partner at the law firm Ice Miller, told the Associated Press that she has advised clients to carefully list in their declarations all of the document numbers for forms that went to CBP to describe imported goods and their value. As the AP paraphrased her warning: If there is an entry on that file that does not qualify, it may cause the entire entry to be rejected or that line item might be rejected by Customs.²

Pete Mento, a licensed customs broker and director of global trade advisory services at Baker Tilly, was even more direct in a widely circulated post on LinkedIn, which Time magazine quoted this week: CAPE is clearly designed to make intake easy. Almost deceptively easy. But nothing in this update suggests CBP is relaxing scrutiny on the back end.⁵

Adam Hanover, managing director of restructuring and dispute resolution at CohnReznick Advisory, put the concern bluntly to CBS News: April 20 is when things are going to start to hit the fan.¹¹

The operational risk for importers is real. Sanne Manders, president of the global trade and logistics company Flexport, was paraphrased by CBS News as warning that it is not uncommon for customs brokers to make mistakes in paperwork by, for example, applying the wrong tariff codes to a given import.¹¹ In the CAPE system, a wrong HTS code at filing time is not a minor annoyance — it can knock an entire entry out of the refund queue.

What the refund does not cover

The refund program launching today is specifically limited to tariffs imposed under the IEEPA authority. A number of other Trump-era trade measures — several of which remain in active effect — are explicitly outside the scope of CAPE. The U.S. Chamber of Commerce has summarized the exclusions: Refunds do not cover Section 232, Section 301, anti-dumping, or most-favored-nation tariffs — only IEEPA-based duties.⁸

That distinction matters enormously. The Section 301 tariffs on Chinese imports, originally imposed in 2018, remain in force. Section 232 duties on steel and aluminum are unchanged. A new 10 percent tariff imposed under Section 122 of the Trade Act of 1974 — a separate legal authority — took effect for entries filed on or after February 24, 2026, and is not refundable. As trade specialists at FreightFigures explained, Section 122 is a separate legal authority under the Trade Act of 1974 and is not part of the IEEPA refund process.¹²

In other words: when CAPE strips IEEPA duties out of an entry and recalculates, it leaves every other tariff layer — MFN base duty, Section 301, Section 232, Section 122, anti-dumping — untouched.

What about consumers?

For the tens of millions of Americans who paid IEEPA surcharges on packages delivered to their homes over the past year, there is no direct path to the CAPE portal. Lizbeth Levinson, co-chair of the international trade practice group at Fox Rothschild, was blunt with CBS News: These are absolutely not automatic refunds. You have to jump through hoops.¹¹

Consumers will depend on the carriers and sellers that paid the duties on their behalf. FedEx, one of the largest collectors of IEEPA duties on consumer shipments, has said publicly that it intends to pass refunds through. In a statement reported by the AP, the company said: Supporting our customers as they navigate regulatory changes remains our top priority. We are working with our customers as CBP begins processing refunds and plan to begin filing claims on April 20.²

Separately, a wave of class-action lawsuits is already working through federal court. The Associated Press reported that class-action cases that aim to force companies, ranging from Costco to Ray-Ban maker Essilor Luxottica, to reimburse shoppers are winding their way through the courts.²

For importers: what you do in the next 72 hours

CBP has been clear about the prerequisites. Based on the agency’s own IEEPA Duty Refunds page and guidance from the U.S. Chamber of Commerce, an importer who wants to be paid in 2026 should do the following immediately:

1. Update your CBP importer record (Form 5106). The email on file must be yours — not your broker’s — because CBP uses it for authentication.
2. Confirm your ACE Portal account is live. New account setup can take three to four weeks, per the U.S. Chamber’s guidance.⁸ If you do not have one, the race has already started without you.
3. Enroll in ACH Refund. All IEEPA refunds are paid electronically. No ACH, no money — even after your claim is approved.
4. Reconcile your IEEPA exposure. Pull the ES-701 and ES-702 reports from ACE, identify every entry with a Chapter 99 IEEPA code, and separate unliquidated entries from those more than 80 days past liquidation.
5. Decide who files. Only the importer of record or their licensed broker can submit a CAPE Declaration. Many brokers are already at capacity.

The first-phase window is open now. It will not stay quiet for long.

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Sources

1. U.S. Customs and Border Protection, IEEPA Duty Refunds — Consolidated Administration and Processing of Entries (CAPE) Phase 1, cbp.gov, April 2026. cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds
2. Associated Press (via CNBC and ABC News affiliates), “Businesses can claim refunds for Trump tariffs ruled unconstitutional starting Monday,” April 19, 2026.
3. Cherry Bekaert, “IEEPA Tariff Refund Update: Phase I CAPE Set for April 20, 2026,” April 2026.
4. ABC7 News (AP report), “Trump tariff business refunds: Businesses can claim refunds starting Monday,” April 20, 2026.
5. Time Magazine, “How U.S. Businesses Can Apply for Tariff Refunds,” April 17, 2026.
6. Norton Rose Fulbright, “CBP issues tariff refund instructions,” April 2026.
7. Troutman Pepper Locke, “CBP Issues Guidance on IEEPA Duty Refunds via New CAPE Process: What Importers Must Do Before April 20,” April 2026.
8. U.S. Chamber of Commerce, “IEEPA Tariff Refunds: Guide & FAQ for Small Businesses,” uschamber.com, 2026.
9. CBS News, “Tariff refund delays could cost U.S. taxpayers $700 million a month in interest,” March 4, 2026 (citing Cato Institute research).
10. Penn Wharton Budget Model, University of Pennsylvania, “Supreme Court Tariff Ruling: IEEPA Revenue and Potential Refunds,” February 20, 2026.
11. CBS News, “Trump administration set to launch tariff refund portal. Here’s what to know,” April 2026.
12. FreightFigures, “CBP CAPE Tool Goes Live April 20, 2026: How to File Your IEEPA Tariff Refund in Phase 1,” April 2026.