Following the recent Supreme Court ruling striking down IEEPA tariffs, CBP has established strict, rolling deadlines for recovering invalidated duties. Refunds are not automatic. Missed windows can force your entries into complex legal queues or eliminate your recovery options entirely. We run deadline-first triage with entry-specific action queues so your highest-risk windows are handled before lower-priority work.
🚨 URGENT MILESTONE: Phase 1 CAPE Portal Opens April 20
On Monday, April 20, 2026, at 8:00 AM EST, CBP will officially open Phase 1 of the Consolidated Administration and Processing of Entries (CAPE) tool within the ACE Secure Data Portal. This is the exclusive electronic pathway to submit valid IEEPA duty refund claims via batch CSV uploads.
The 80-Day Eligibility Clock (Phase 1 Window)
Phase 1 of the portal accepts CAPE Declarations only for unliquidated entries and entries that are within 80 days of liquidation.
The Risk: This is a rolling clock. CBP requires this 80-day threshold to process voluntary reliquidations within their strict 90-day legal window. If an entry crosses day 81 before you file, it immediately ages out of Phase 1 eligibility and gets pushed to future, unannounced CBP processing phases (Phase 2), drastically delaying your refund.
Deadline control model (IEEPA/CAPE Edition)
- 01Collect entry population and confirm liquidation posture: Pull all ACE data to isolate entries containing IEEPA Chapter 99 HTS codes and hard-code the exact liquidation date for every single entry.
- 02Classify by the 80-Day Rule: Separate your entry population into Phase 1 eligible (Unliquidated or ≤80 days post-liquidation) and Phase 2/Protest eligible (>80 days or complex entries like Drawback).
- 03Build a ranked execution queue: Prioritize entries nearing the 80-day cliff to prevent them from aging out of the immediate April 20 CAPE rollout. Lock older entries into a 180-day formal protest queue to preserve legal rights.
- 04Lock prerequisites & CSV formatting: Confirm the Importer of Record has active ACE Portal access and is enrolled in ACH Refunds (which is entirely separate from standard ACH payments). Format clean data into the strict CAPE .CSV template, ensuring no batch exceeds the 9,999-entry limit.
- 05Monitor validation and the 60-90 Day payout: Execute uploads starting April 20. Monitor CBP's two-step batch validation to instantly correct rejected files (amendments are not allowed once submitted). Track accepted declarations for the 60-90 day milestone for electronic ACH refund issuance with statutory interest.
Official IEEPA Refund Timelines
CBP publishes official FAQs and CSMS guidance defining the CAPE refund mechanics.
CAPE Phase 1 Portal Goes Live in ACE.
Strict Two-Step Validation. ACE validates file formatting, then validates that each individual entry contains IEEPA duties.
For standard accepted entries absent compliance concerns, CBP targets electronic ACH payouts within 60 to 90 days following acceptance.
The statutory window to file a formal protest (19 U.S.C. § 1514). For entries older than 80 days that are excluded from Phase 1, a protest must be actively filed before this clock expires to legally preserve refund rights while waiting for Phase 2.
Future processing opens for complex scenarios, including AD/CVD entries, duty drawbacks, reconciliation claims, open protests, and historically liquidated entries.
Related resources
- Customs Protest Guide for protest-specific filing controls
- Documents Library for evidence prep sequencing
- IEEPA Refund Process for entry-level pathway triage
Free Download: IEEPA Tariff Refund Checklist
Don't miss the 80-day CAPE portal window. Download our comprehensive, one-page readiness checklist to ensure your entries are fully prepared for submission.