This morning, U.S. Customs and Border Protection opened a $166 billion refund portal. The filing itself is simple. The data isn’t — and that’s where most mid-market manufacturers are about to learn an expensive lesson about their ERP.

On April 20, 2026, U.S. Customs and Border Protection opened the first phase of its new Consolidated Administration and Processing of Entries (CAPE) tool inside the ACE Portal. CAPE is the mechanism CBP built to refund duties collected under the International Emergency Economic Powers Act (IEEPA) after the Supreme Court ruled those duties unlawful in Learning Resources v. Trump on February 20, 2026.

The numbers are not small: roughly $166 billion in refunds in play across about 53 million entries from 330,000+ importers, according to CBP’s rollout documents. A lot of that money belongs to mid-market manufacturers and distributors who paid these duties quietly, entry by entry, and never had dedicated customs counsel riding on their shoulder. If that sounds like your business, read the next 1,500 words carefully.

Here’s what just happened, who qualifies, exactly how to file, and — because this is where most importers are going to struggle — what your ERP has to do with any of it.

What Just Happened

Between 2025 and February 2026, importers paid IEEPA-based tariffs on top of their normal MFN duties and any applicable Section 301 / Section 232 / Section 122 layers. In February 2026, the Supreme Court invalidated those IEEPA duties. The Court of Appeals for the Federal Circuit issued its formal mandate on March 2, 2026, and CBP asked for 45 days to build a refund mechanism that wouldn’t drown under the volume. The Court of International Trade granted the extension, CBP built CAPE, and Phase 1 went live this week.

CAPE is not the Automated Broker Interface. It is a new tab inside the ACE Secure Data Portal where an importer of record (IOR) — or a licensed customs broker acting on the IOR’s behalf — uploads a CSV file called a CAPE Declaration. Each CAPE Declaration lists up to 9,999 eligible entries. CBP validates, strips the IEEPA Chapter 99 line items, recalculates the duty owed without IEEPA, and issues the refund by ACH.

That’s the system. It’s genuinely simple — if your data is clean.

Who’s Eligible in Phase 1

CBP structured this rollout in phases on purpose. Phase 1 is narrow. It covers two entry categories:

Unliquidated entries. If CBP has not yet liquidated the entry, it’s eligible. These are the cleanest refunds in the system — no protest clock, no reconciliation overhead.
Entries liquidated within the last 80 days. If CBP liquidated the entry on or after roughly January 31, 2026, it’s still inside the 180-day statutory protest window under 19 U.S.C. § 1514, and CAPE can reliquidate it without special administrative authority.

Industry estimates put those two buckets together at roughly 63% of eligible entries. Everything else — entries liquidated more than 80 days ago, entries caught in protests, entries involving drawback or Foreign Trade Zones, entries with post-summary corrections — is deferred to Phase 2 and Phase 3. CBP has not published firm dates yet, but the expectation across the customs bar is summer through fall 2026.

A few eligibility details worth knowing up front:

Only the IOR or the broker who filed the entry can file the CAPE Declaration. A third party you bring in today cannot file on entries that a different broker filed last year.
Post-Summary Corrections are not a substitute. CBP is explicit that PSCs do not work for IEEPA refunds. CAPE is the exclusive path for any entry carrying an IEEPA Chapter 99 code.
Section 122 stays. The 10% Section 122 tariff that kicked in on February 24, 2026 is a separate legal authority under the Trade Act of 1974. It is not refunded. When CAPE recalculates your entry, Section 122 remains on the bill.
Debt offsets still apply. If your company owes CBP money on other entries, refunds can be netted against that debt under 19 C.F.R. § 24.72.

How to Actually File

The mechanics are straightforward. The data work is where it gets hard — which is the part nobody is talking about.

Step 1. Confirm your ACE Portal Importer sub-account is active. If you or your broker already file in ACE, you’re probably fine. If not, apply through CBP’s ACE Portal page and enroll in ACH refunds. This takes days, not hours — don’t wait.

Step 2. Pull an IEEPA-duty-only entry report from your broker. Ask for every entry between roughly March 2025 and February 24, 2026, with the IEEPA portion of duty broken out separately from MFN, Section 301, Section 232, and Section 122. If your broker can’t produce this cleanly, that’s a signal about what the next step will look like for you.

Step 3. Flag Phase 1-eligible entries. Either (a) still unliquidated, or (b) liquidated on or after January 31, 2026. These are the ones ready to go today.

Step 4. Build the CAPE Declaration CSV. CBP provides a template in the CAPE tab. You list entry numbers — CBP doesn’t require any additional fields in the file itself — up to 9,999 entries per declaration. Large importers will file multiple declarations.

Step 5. Verify ACH information. Refunds hit the bank account on file in ACE. If your banking changed in the last year and ACE wasn’t updated, the refund will stall or reject.

Step 6. Decide IOR-files vs. broker-files and put it in writing. Only one of you can file on a given entry. No ambiguity on day one.

Step 7. Submit, then wait. CBP’s stated timeframe is 60–90 days from acceptance to refund, unless a compliance issue forces deeper review. Clean declarations can land closer to 45 days.

The Part Nobody Is Writing About: Your Data

Here is the part where law-firm client alerts stop and operational reality begins.

Every importer we work with who paid serious IEEPA duty has the same problem on April 20: the data needed to file CAPE is not sitting in one place. It is scattered across AP records, receiving documents, broker spreadsheets, customs entry PDFs, and shipment-level freight invoices. The fields CBP cares about — entry number, IEEPA duty amount, liquidation date, HTS code, IOR identity — are often in three different systems maintained by three different people.

That’s not a minor inconvenience. At ~$1M+ in IEEPA duties paid, which is typical for a mid-sized importer with meaningful China/Vietnam exposure across 2025, the reconciliation to build an accurate CAPE Declaration is a multi-week project for a finance team that does not do this work all year.

We’ve been on the other side of this. Several of our customers — ranging from industrial equipment and medical device to home furnishings and consumer goods — paid more than $1M in IEEPA duties under multiple recent tariff regimes. Because their SAP Business One implementations capture entry-level customs data where it belongs (landed cost tied to the PO and receipt, HTS codes tagged to item masters, broker entry numbers and liquidation dates stored against the shipment), they can produce a CAPE-ready CSV in about thirty minutes. The ERP is the reason they can move on day one rather than day forty-five.

If your B1 (or other ERP) is not set up that way today, the work to get there is not huge — but it has to happen before the next tariff cycle, not after. That’s the hard-won lesson from the past eighteen months: tariff regimes now change faster than most finance processes can adapt, and the companies that track landed cost, HTS, and entry data cleanly at the ERP layer are the ones that file refunds first, forecast accurately, and hold their margins when the next Chapter 99 code shows up.

FAQ

Who files the CAPE Declaration — the importer or the broker?
Only the IOR or the licensed customs broker who filed the original entry. Third-party consultants brought in after the fact cannot file.

What’s the deadline?
CBP has not set a hard cutoff for Phase 1 filings, but Phase 1 is narrow by design — it only covers unliquidated entries and entries within 80 days of liquidation. Every day you wait, more entries liquidate past the 80-day window and fall out of Phase 1 eligibility.

When will I actually see the money?
CBP’s stated window is 60–90 days from acceptance of the declaration, unless a compliance issue triggers further review. Clean declarations can pay closer to 45 days.

What about entries liquidated more than 80 days ago?
Those wait for Phase 2. No firm date yet. If you filed a protest within the 180-day statutory window, that remains an option on its own track; otherwise, hold the entry data and be ready when later phases open.

Does CAPE refund my Section 301, Section 232, or Section 122 duties too?
No. CAPE only removes the IEEPA Chapter 99 line items. All other duty layers — including the 10% Section 122 duty on post-February-24-2026 entries — remain in place.

Do I need a law firm?
Phase 1 does not require a CIT case. For most importers with clean data, the CAPE filing is an internal-plus-broker exercise. If you’re in Phase 2 territory, involved in active protests, or dealing with drawback or FTZ complications, talk to customs counsel.

What if my ERP doesn’t track landed cost or HTS codes at the entry level?
That’s the real problem to solve — not just for this refund, but for the next tariff regime, and the next, and the next. Get it right once and you file refunds, forecast landed costs, and survive tariff shifts without scrambling.

How We Can Help

We’ve been doing SAP Business One implementations for manufacturers and distributors since B1 first arrived in North America. When tariff regimes shift — and they will keep shifting — the difference between a company that files on day one and a company that files on day 120 is almost entirely an ERP question: do you capture the entry-level data you need, where you need it, cleanly enough to report on it?

We can help you look back and look forward. For Phase 1, we can help you pull the entry data out of B1 quickly and hand your broker a clean CAPE-ready list. For the next regime, we can help you build the landed cost, HTS, and customs entry tracking into B1 so the next refund cycle — or the next tariff surprise — is a thirty-minute export instead of a two-month project.

If you import, you paid IEEPA duties, and you want to know what a clean tariff-data setup looks like in B1, get in touch. It’s a short conversation and it usually pays for itself on the first refund cycle.

CBP Owes You a Tariff Refund. Can Your ERP Prove It?

What Just Happened

Who’s Eligible in Phase 1

How to Actually File

The Part Nobody Is Writing About: Your Data

FAQ

How We Can Help

Sources

Let's talk.