U.S. Customs and Border Protection (CBP) has launched Phase 1 of the Consolidated Administration and Processing of Entries (CAPE), a new ACE functionality designed to process refunds of duties imposed under the International Emergency Economic Powers Act (IEEPA). CAPE consolidates refund processing and is being deployed in phases to address increasing levels of complexity. Phase 1 is limited in scope and timing, making preparation critical.

CAPE is available in the Automated Commercial Environment (ACE) effective April 20, 2026, and filings are limited to the Importer of Record (IOR) or the customs broker who filed the entry.

Before You File a CAPE Declaration

To avoid delays or additional review, Willson International recommends that importers complete the following readiness checks before submitting any CAPE declaration:

ACE Secure Data Portal Access

Apply for or confirm that you have access to your ACE Secure Data Portal account.

ACH Refunds & CBP Form 4811

Enrollment for ACH duty payments does not automatically enroll an IOR for ACH refunds. A separate ACH Refund profile must be completed in ACE before CBP can issue electronic refunds.

If refunds need to be issued to a party other than the IOR, a valid CBP Form 4811 (Special Address Notification) must be on file with U.S. Customs. This tells CBP the notify party for the refund.

Important!

The IOR must maintain a U.S. based bank account to participate in ACH Refunds. Because CBP requires refunds to be issued electronically, failure to enroll in ACH Refunds—or failure to designate a properly authorized 4811 party such as Willson International—will result in failed deposit attempts and delayed refunds.

Compliance Check – Validate Entry Data

Review impacted entries for overall compliance including key areas such as valuation, classification and origin of goods.

CAPE submissions require an attestation that the information being submitted is true and correct, and CBP has cautioned that claims presenting unresolved compliance issues may be delayed or subject to additional reviews or enforcement.

In part, the certification includes the following language:

1) the country of origin, entry type, HTS classification(s), and valuation for each entry number is true and correct, and

2) the goods were not entered in violation of any applicable United States law, order or rule.

Recommendation: Complete Post Entry Corrections First

Where appropriate, complete any post entry actions (Post Summary Corrections or Protests unrelated to IEEPA) prior to submitting a CAPE declaration. CAPE is a refund mechanism—not a substitute for correcting entry errors.

Phase 1 – What’s Eligible

Phase 1 is intentionally narrow and focused on the cleanest refund scenarios:

·      Unliquidated entries subject to IEEPA duties

·      Entries liquidated within 80 days of the CAPE declaration submission

These parameters are designed to keep Phase 1 refunds within existing legal and administrative frameworks, including protest timelines.

Phase 1 – What’s Excluded

Entries falling into more complex categories are not eligible for Phase 1 and are expected to be addressed in later phases or through other remedies:

·      Entries liquidated beyond 80 days

·      Entries flagged for reconciliation

·      Entries tied to drawback claims

·      Entries subject to an open protest

·      Certain AD/CVD related entries

·      Entries not filed in ACE or missing liquidation status

CBP has not yet announced timelines for subsequent phases.

You May Also Consider

Given the limited scope of Phase 1, importers should evaluate additional protective or parallel strategies:

·      Consulting with trade counsel

An attorney can help assess whether filing or maintaining a case at the U.S. Court of International Trade (CIT) is appropriate, particularly for entries outside Phase 1 or with litigation already in progress.

·      Monitoring liquidations and protesting when appropriate

Continue monitoring liquidation notices and file protests for affected entries, especially those approaching or exceeding 80 days post liquidation, to preserve refund rights pending future CAPE phases.

Key Takeaway

CAPE Phase 1 offers a meaningful—but limited—opportunity to recover certain IEEPA duties starting April 20, 2026. Advance preparation, compliance validation, and coordination with Willson International and counsel are critical to avoiding missed opportunities or unintended exposure.

For additional information or to request a quote for CAPE filing please reach out to our U.S. Regulatory Team at regulatoryus@willsonintl.com. 

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