As of April 9, exactly 56,497 importers have completed electronic refund registration steps with CBP, representing $127 billion in duties tied to tariffs struck down by the Supreme Court in February. On Monday, those importers gain access to the new claims portal—the Consolidated Administration and Processing of Entries (CAPE) system—to begin formally submitting refund requests.
CBP confirmed in a Tuesday filing before the Court of International Trade that CAPE Phase 1 development is complete. The agency has entered what official Brandon Lord described as "an intensive testing posture, focused on performance and scenario-based testing of all CAPE components and the remediation of any defects identified during testing." Phase 1 will handle an estimated 63% of total refunds, targeting unliquidated entries and entries within 80 days of liquidation.
Documentation Requirements: SKU-Level Granularity Required
The refund claims process demands more than standard entry data. CBP will require importer-of-record filings, detailed shipment contents, and proof of duties paid. Critically, importers must also demonstrate whether tariff costs were absorbed internally or passed through to customers—at the individual SKU level.
For compliance engineering teams, this means your systems must capture and correlate HTS classifications with pricing decision data at product-level granularity. Large shipments containing thousands of SKUs will require automated documentation workflows to meet CBP's evidentiary standards. Any gaps between your tariff cost records and customer pricing data create audit exposure.
The 80-Day Liquidation Window
Phase 1 eligibility hinges on liquidation status. Entries that remain unliquidated qualify immediately. Entries within 80 days of liquidation also fall under Phase 1 processing. Compliance systems need to track liquidation dates programmatically to determine which entries qualify for the initial refund wave versus later phases.
Integration Considerations for Trade Systems
The CAPE portal launch introduces new data submission requirements that customs software systems must accommodate. At minimum, your refund claim workflow needs to pull importer-of-record identifiers, entry numbers, HTS codes with associated duty amounts, and SKU-level cost absorption evidence from your existing data stores.
Bryan Graiff of Armanino warned that companies rushing to secure inventory during tariff uncertainty may have incomplete records: "In a rush to get those products, maybe some of the paperwork wasn't always filled out 100% accurately." For engineering teams, this translates to data validation requirements before claims submission—mismatches between entry records and actual shipment contents will delay or disqualify refunds.
The total refund pool stands at an estimated $166 billion. With $127 billion already registered through electronic refund steps, the remaining $39 billion represents either unregistered importers or entries requiring Phase 2 or later processing. CFOs and supply chain leaders must coordinate closely to align entry documentation with financial records before submission.