US Customs and Border Protection will launch its Consolidated Administration and Processing of Entries (CAPE) tool on April 20, 2025, enabling importers to begin filing refund declarations for tariffs imposed under the International Emergency Economic Powers Act (IEEPA). The tool addresses a Court of International Trade order from March requiring the federal government to refund up to $170 billion—plus interest—to approximately 330,000 importers.
For compliance engineering teams managing customs data integrations, CAPE Phase 1 introduces specific technical prerequisites that require immediate attention. The system will process only unliquidated entries and entries within 80 days of their liquidation date, meaning teams must implement logic to identify qualifying entries within their systems before the April 20 launch.
ACE Account and Portal Requirements
CBP has established two distinct system requirements for CAPE access. First, filers must maintain an active Automated Commercial Environment (ACE) account. Second, importers must separately enroll their bank details through a dedicated ACE portal to receive digital refund disbursements. This dual-enrollment architecture means compliance teams should verify both account status and banking portal enrollment for all clients expecting refunds.
Only the importer-of-record or their designated customs broker can submit refund declarations through CAPE. This restriction requires brokers to confirm their authority status in ACE for each affected client before the system goes live.
Scale of Affected Entries
Over 53 million import entries fall under IEEPA tariffs subject to potential refund. This volume—combined with the 80-day liquidation window constraint—creates a processing challenge that will extend across multiple CAPE phases.
Phase 1 Limitations and System Planning
CBP explicitly stated that CAPE Phase 1 handles only "certain straightforward and recent import entries," with more complex refund scenarios deferred to subsequent phases. The agency has not published a timeline for later phases, leaving compliance teams without clarity on when older or more complicated entries will become eligible.
Critical constraint: The 80-day liquidation window means entries liquidated before approximately February 1, 2025 may already be ineligible for Phase 1 processing. Teams should immediately audit entry liquidation dates against this cutoff.
For systems that cache HTS rates and duty calculations, the IEEPA refund scenario introduces a reconciliation complexity: entries filed under rates that were later invalidated by the Supreme Court's February ruling must now be flagged, tracked, and matched against CAPE eligibility windows. Rate data accuracy at the time of original filing becomes essential documentation for refund claims.
Preparing for April 20
Compliance engineering teams should complete three tasks before the CAPE launch: verify ACE account status for all importer-of-record clients, confirm banking enrollment in the separate ACE refund portal, and build queries to identify unliquidated entries and entries within 80 days of liquidation. Given that this refund could become the largest in US government history, CBP will likely face system load challenges—teams should plan for API rate limits and potential processing delays in their integration designs.
CBP continues providing updates to the Court of International Trade on CAPE implementation, suggesting additional technical guidance may emerge before April 20.