How to File a Tariff Refund Claim: A Step-by-Step Guide to the CAPE Declaration

If you are an American company that imported goods between March 2025 and February 2026, there is a reasonable chance the federal government owes you money. This is the filing guide.

The CAPE portal — the system U.S. Customs and Border Protection opened at 8:00 a.m. Eastern on April 20, 2026 for the return of $166 billion in tariffs struck down by the Supreme Court — is, from one angle, a simple CSV upload. From another angle, as the customs broker Pete Mento put it in a widely quoted LinkedIn post, it is almost deceptively easy.¹

This article walks through the filing process end-to-end, in the order the work actually happens. It is written for importers who are doing this for the first time.

Are you eligible? The five-minute check

Before you touch the portal, confirm your claim falls inside Phase 1. CBP has defined the Phase 1 scope narrowly. Per the agency’s official guidance, Phase 1 is limited to certain unliquidated entries and certain entries within 80 days of liquidation.²

You likely qualify for Phase 1 if all of the following are true:

• You were the importer of record (or your broker paid duties on your behalf).
• Your entries include at least one dutiable IEEPA Harmonized Tariff Schedule Chapter 99 code.
• Those entries are either still unliquidated, or were liquidated on or after a date roughly 80 days before April 20, 2026 — meaning on or after approximately February 1, 2026.
• The entries are not tied to a drawback claim, antidumping/countervailing duties pending liquidation, or a Duty Deferral (Type 08) or Temporary Importation Bond (Type 23) designation.

If some of your entries are older than the 80-day window, do not give up — but do not try to shove them into CAPE. Those entries will be processed in Phase 2, for which CBP has not yet set a date, or can be preserved through a CBP protest (if within the 180-day protest window) or a filing at the U.S. Court of International Trade.

Step 1: Update your CBP Form 5106

Form 5106 is the CBP importer ID input record. It is how customs knows who you are, where to send notices, and — critically for refunds — what email address to use for authentication.

The U.S. Chamber of Commerce made this the first item on its preparation checklist, noting that importers should Make sure your CBP importer record (Form 5106) for your company is up-to-date and includes an email address that is not your broker’s email (required for authentication).³

Why does this matter? Because many importers, particularly smaller ones, set up their 5106 years ago using a broker’s generic email inbox. When CBP emails you a portal authentication link and it lands in your broker’s queue, you lose days.

Your licensed customs broker can update Form 5106 on your behalf through the ACE Portal. If you do not have a broker, you can file the form directly with the CBP Client Representative Branch.

Step 2: Open (or verify) your ACE Portal account

The Automated Commercial Environment — ACE — is the CBP system through which all import entries are filed, tracked, and settled. CAPE lives inside ACE as a new tab; there is no separate portal to bookmark.

You need an ACE Portal account with an Importer sub-account. According to CBP’s guidance: To provide your refund bank account information, you will need to have the ‘Importer’ sub-account in the ACE Portal.² This sub-account is different from the organizational broker and filer sub-accounts a customs broker operates.

Setup is not instant. The U.S. Chamber’s guidance explicitly warns: Some importers have reported new ACE account setup takes 3-4 weeks.³ If you are starting today, you are targeting a filing window in mid-to-late May.

To start, visit cbp.gov and search for “Applying for an ACE Portal Importer Account.” You will need:

• Your company’s CBP-assigned importer number
• An authorized trusted business representative (a specific employee, not a generic inbox)
• A copy of your most recently updated Form 5106

Step 3: Enroll in ACH Refund

Every IEEPA refund is paid by Automated Clearing House — an electronic transfer. CBP has stated unambiguously that all refunds are required to be paid electronically via Automated Clearing House (ACH).² If your company is not enrolled in ACH Refund, no amount of properly filed paperwork will get you paid.

Inside the ACE Portal, navigate to your Importer sub-account, then to the ACH Refund Authorization tab. You will enter:

• A U.S. bank routing number
• An account number designated specifically for refunds
• An authorized signer

Note that this refund ACH account is separate from any ACH account you may already have on file for paying duties to CBP. The agency treats the two as distinct channels.

As of April 14, CBP reported, only about 82 percent of entries with paid IEEPA duties had filers registered for electronic payment — roughly $127 billion in refunds worth of eligible volume.¹ The remaining 18 percent is sitting in the queue waiting for ACH enrollment that has not happened yet.

Step 4: Pull your IEEPA entry list from ACE

Once your ACE access is live, your first real filing task is reconciliation. You need a clean list of every entry on which your company paid IEEPA duties — and only those entries.

ACE offers several reports that can help. CBP’s guidance identifies the key ones: An importer or broker with an ACE Account may access the ES-701 Courtesy Notice of Liquidation Report or the ES-702 Official Notice of Extension, Suspension and Liquidation Report to identify the liquidated amount on the entry summary.²

What you are looking for on each entry is a Chapter 99 HTS code. IEEPA tariffs were administered through a specific subset of Chapter 99 provisions. Any entry with one of those codes is a candidate. Any entry without one is not.

Tag each entry in your own internal spreadsheet with:

• Entry number
• Filing date
• Liquidation status (unliquidated / liquidated on [date])
• Chapter 99 HTS code(s) present
• IEEPA duty amount paid
• Any flags: drawback claim? protest pending? AD/CVD? Type 08 or Type 23?

That last column — the flags — is where filings go wrong. An entry flagged for drawback but included in a CAPE Declaration will be rejected, and every rejection creates rework. As the Associated Press reported, Meghann Supino of Ice Miller warned that 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.⁴

Step 5: Build your CAPE Declaration CSV

The CAPE Declaration is deceptively simple in format. It is a comma-separated-values file — you can build it in Excel and save as .csv — that CBP validates when you upload.

Per CBP’s Trade Information Notice: The CSV file, called a CAPE Declaration, will contain a list of entry numbers for which IEEPA refunds are requested. Each individual CAPE Declaration is limited to 9,999 entries, but multiple CAPE Declarations may be submitted. A downloadable CAPE Declaration template file will be available through the ‘Upload’ button in the CAPE tab.⁵

Best practice as articulated by the law firm Troutman Pepper Locke: CBP provides a CAPE Upload Template (Excel) in the portal; it must be completed and saved as a .csv (comma-delimited) file.⁶ Do not try to build your own CSV from scratch. Use the template.

A few rules that matter:

• Each entry may appear on only one accepted declaration. Duplicates across declarations are rejected automatically.
• A declaration cannot be amended after acceptance. If you need to add entries, file a new declaration.
• Brokers can include entries for multiple importers in a single declaration — up to 9,999 total entries across all importers.
• CAPE filings cannot be submitted via ABI/EDI. They must come through the ACE Portal web upload.

Step 6: Upload, validate, and claim your number

Once your CSV is ready, you log into ACE, open the CAPE tab, and use the Upload button to submit your declaration. What happens next is automated, and it happens in two stages.

CBP describes the sequence as follows: ACE will conduct two series of validations. The first series checks the CAPE Declaration, and the second series checks the individual entries listed in the file.⁵

If the file itself fails validation — wrong format, missing header row, corrupted CSV — the entire declaration is rejected. You fix the file and resubmit.

If the file is valid but individual entries fail — wrong entry number, not Phase 1 eligible, duplicate of an earlier declaration, wrong importer of record — those specific entries are rejected line by line. The valid entries remain and continue through processing. You can see exactly which lines were rejected and why. Rejected entries must be resubmitted on a separate new declaration.

When a declaration is accepted, ACE issues a CAPE claim number. Save this number. It is how you track the refund through the rest of the process.

Step 7: Track and receive your refund

From acceptance forward, CBP handles the rest. Internally, ACE strips the Chapter 99 IEEPA codes from each accepted entry, recalculates duty owed, liquidates or reliquidates the entry, and then queues the refund for ACH payment.

Two reports inside ACE let you track progress. Starting April 20, 2026, CBP made a new CAPE-specific report available. Per the agency: Effective 4/20/26, Importers or Brokers with ACE Accounts will also be able to access the new REV-615 Trade CAPE Detail Refund Report. This report will provide consolidated CAPE refund information as well as entry-level refund information.²

The older REV-603 Trade Refund Report continues to track completed refunds system-wide.

CBP’s timing guidance, taken directly from the agency: 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.²

And one more dollar-and-cents detail importers tend to miss: the refund includes interest. Under 19 U.S.C. § 1505(c), interest accrues from the date you deposited the estimated duty until the date of refund. As the U.S. Chamber of Commerce notes, the interest rate is 6% at present.³ For importers with large 2025 IEEPA exposures, the interest alone can run into six and seven figures.

Common filing mistakes (and how to avoid them)

1. Letting the broker use their own email on Form 5106

Authentication emails go to the address on file. If that address is a broker’s shared inbox, you are relying on them to forward — and they are drowning right now.

2. Skipping ACH enrollment

A surprising number of importers have completed every other step, only to realize after their claim is accepted that their bank account is not on file in the ACE ACH Refund tab. The refund will simply sit. Fix this first.

3. Building the CSV from scratch

CBP’s template is the safe path. Column order matters. Hand-built CSVs fail file-level validation more often than they succeed.

4. Including ineligible entries

The most common cause of line-item rejections is including entries tied to drawback, protests, AD/CVD liquidation instructions, or old liquidation dates. Flag these in your reconciliation before you build the declaration, not after.

5. Assuming liquidated entries over 80 days are lost

They are not. They are just not Phase 1 eligible. As Time magazine reported, quoting broker Pete Mento: Because it preserves your rights. You can always withdraw later. You can’t go back and file one after the window closes.¹ The advice is to file protests for any entry inside the 180-day window, even as you work the CAPE queue on the rest.

6. Waiting to register

As of April 14, more than 56,000 importers had registered for refunds — out of more than 330,000 known IEEPA payers. The race for broker capacity will intensify as filings ramp up through the summer.

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Sources

1. Time Magazine, “How U.S. Businesses Can Apply for Tariff Refunds,” April 17, 2026.
2. U.S. Customs and Border Protection, IEEPA Duty Refunds, cbp.gov, April 2026. cbp.gov
3. U.S. Chamber of Commerce, “IEEPA Tariff Refunds: Guide & FAQ for Small Businesses,” uschamber.com, 2026.
4. Associated Press (via ABC7 News), “Trump tariff business refunds: Businesses can claim refunds starting Monday,” April 20, 2026.
5. U.S. Customs and Border Protection, Trade Information Notice: Consolidated Administration and Processing of Entries (CAPE) Phase 1, cbp.gov, April 2026.
6. Troutman Pepper Locke, “CBP Issues Guidance on IEEPA Duty Refunds via New CAPE Process: What Importers Must Do Before April 20,” April 2026.