CBP's CAPE Declaration system went live April 20, 2026 for IEEPA tariff refunds following the February 20 SCOTUS ruling that invalidated presidential tariff authority under the International Emergency Economic Powers Act. The portal accepts CSV files through ACE with a hard limit of 9,999 entries per submission—a constraint that will force compliance teams managing high-volume importers to batch their refund requests across multiple filings.

Phase 1 eligibility is restricted to two categories: unliquidated entries (where CBP has not finalized duty assessment) and entries within 80 days of liquidation. According to CBP, these criteria cover 63% of all IEEPA entries filed since the tariffs took effect in 2025. If your entry data shows liquidation dates outside this 80-day window, you'll need to wait for Phase 2, which will address finalized liquidations, entries without liquidation status, and entries tied to open protests.

Critical distinction: IEEPA refunds do not apply to Section 122, Section 301, or Section 232 tariffs. Your systems must differentiate between IEEPA-based duties on Brazil, Canada, China, the EU, Mexico, and UK goods versus duties assessed under Trade Act or Trade Expansion Act authority. Conflating these in refund submissions will result in rejection.

The technical workflow requires ACE portal access. Importers of record or their customs brokers submit a CAPE Declaration as a .CSV file containing entry data for refund requests. CBP's reference guide specifies the required field structure, though the agency has not issued a formal news release—the portal opened without standard CBP communication due to the ongoing government shutdown. Once CBP accepts a CAPE Declaration, refunds are expected within 60-90 days unless compliance flags trigger additional review.

For engineering teams maintaining tariff calculation systems, this creates an immediate data integrity problem. Your HTS rate tables need to reflect which duty lines were IEEPA-based versus Section 301 or Section 232. If your cache doesn't distinguish tariff authority at the line level, you cannot programmatically identify which historical entries qualify for Phase 1 refunds. The 80-day liquidation window is a moving target that requires daily recalculation against your entry records.

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9,999-entry ceiling per CSV: Importers with tens of thousands of qualifying entries will need to split submissions. Your batch processing logic should account for this limit and track submission status across multiple CAPE Declarations to avoid duplicate filings or missed entries.

The SCOTUS ruling struck down IEEPA tariffs that generated over $166 billion in collected duties. For compliance teams, the refund opportunity is significant—but only if your underlying tariff data correctly flags IEEPA authority. Section 301 duties on China and Section 232 steel/aluminum tariffs remain in force and are explicitly excluded from refund eligibility. Any automation you build around CAPE submissions must enforce this distinction at the data layer.

CBP has not announced timelines for Phase 2 or subsequent phases. Teams should monitor for updates on liquidated entries and protest-covered entries, as these will require different eligibility logic and potentially different submission procedures.