CBP's Consolidated Administration and Processing of Entries (CAPE) portal has approved $35.46 billion in refunds covering more than 8 million liquidated or reliquidated entries as of Monday, according to a court filing submitted Tuesday. The system, which launched April 20 to process refunds for tariffs invalidated by the Supreme Court earlier this year, has validated over 15 million entries total — but a critical processing gap remains for importers with finally liquidated entries.

The $35.46 billion represents roughly 21% of the estimated $166 billion in total refund liability CBP projected in March. Companies including Oshkosh, Basic Fun, Ford Motor Co., and General Motors are among those expecting returns, with Ford and GM projecting refunds of $1.3 billion and $500 million respectively. Individual importers are also seeing funds hit their accounts — Sarah Wells, founder of Sarah Wells Bags, confirmed receiving her first entry refund this week via LinkedIn.

Current CAPE Processing Status

  • Launched: April 20, 2026
  • Entries validated: 15+ million
  • Refunds approved: $35.46 billion across 8+ million entries
  • Estimated total liability: ~$166 billion
  • Gap: Finally liquidated entries not yet supported

The distinction between liquidated/reliquidated entries and finally liquidated entries is critical for compliance teams tracking refund eligibility. CAPE currently processes entries that have been liquidated or reliquidated but cannot yet handle finally liquidated entries — those where the liquidation has become conclusive and no longer subject to protest or reliquidation. CBP has stated it is developing this capability, but no timeline has been published. This means importers with older entries that reached final liquidation status before the tariff invalidation remain in a holding pattern.

Data Validation Is Non-Negotiable: CBP's filing notes that remaining entries "continue to be consolidated by the CAPE Refund component," indicating that data inconsistencies or validation failures will delay refund processing. Entries must pass validation before reaching the refund queue.

For trade compliance engineering teams, the CAPE rollout underscores why maintaining accurate, audit-ready entry data is essential. The portal's validation requirements mean that any discrepancies between submitted refund claims and original entry data — including HTS classifications, duty rates, and valuation — will flag entries for manual review or rejection. Companies relying on cached tariff rates or outdated classification data risk delays or compliance events during the refund process.

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Pete Mento, director of global trade advisory services at Baker Tilly, warned in a LinkedIn post that the refund process rewards operational rigor over speed. "The firms that ultimately win this market are not going to be the cheapest spreadsheet uploaders," Mento wrote. "They are going to be the firms that understand customs valuation, tariff stacking, entry reconstruction/sequencing, audit defense, operational controls, and how to calmly explain to a CFO why a refund opportunity unexpectedly turned into a compliance event."

For teams managing refund claims programmatically, this means ensuring your HTS rate data matches what CBP has on record for each entry's original filing date. Tariff stacking — where multiple duty layers applied to a single entry — adds complexity, as each rate must be validated independently. If your system cached rates that were subsequently modified or if classification codes shifted during the tariff period, your refund calculations may not align with CAPE's validation logic.

With $130+ billion in refunds still pending and finally liquidated entry processing not yet available, compliance teams should prepare for an extended timeline. Auditing historical entry data against authoritative HTS sources now will prevent validation failures when CAPE expands its processing capabilities.