CBP's CAPE Portal for IEEPA Tariff Refunds: What the Four-Step Process Actually Means and Why You Should Not Wait for It

Tariff Refund Solutions is an attorney-led program that recovers IEEPA tariff refunds for businesses on contingency.

CBP says it is building an online portal to process IEEPA tariff refunds. The portal is not ready. It may not be ready for months. And even when it launches, it will only cover one piece of the refund puzzle.

If you are waiting for the CAPE portal before you take action on your IEEPA tariff refund, you are losing time and potentially losing money. Here is what the portal actually is, what it covers, what it does not cover, and what you should be doing right now instead of waiting.

What Is the CAPE Portal?

CAPE stands for Consolidated Administration and Processing of Entries. It is a new module that CBP is building inside the Automated Commercial Environment (ACE) platform, which is the existing system that CBP uses to process imports, exports, and trade compliance.

The idea is straightforward: create an online tool where importers and customs brokers can submit lists of entries affected by the now-unlawful IEEPA tariffs, and CBP processes the refunds through its system.

CBP has described a four-step process:

1. Claim Portal. Importers or their brokers submit affected entry summaries in CSV format through ACE.
2. Mass Processing. CBP runs the submitted entries through automated checks.
3. Review and Liquidation. CBP reviews flagged entries and reliquidates them without the IEEPA duty component.
4. Refund. CBP issues refunds to importers of record.

On paper, that sounds clean. In practice, it is far from done.

When Will the CAPE Portal Go Live?

CBP originally told the Court of International Trade it would need approximately 45 days from March 6, 2026, putting the estimated launch around mid to late April 2026.

As of the most recent status update, the portal is not finished. CBP reported that the Claim Portal component was 73% complete, mass processing was 45% complete, and the refund processing component was 60% complete. Those numbers do not add up to "launching in three weeks."

Even if CBP hits its target date, there is a meaningful risk of delays. This is a system being built under pressure to process refunds on over 53 million entries involving approximately $166 billion in duties. The scale is enormous, and CBP itself told the court that the process would be "an undertaking of unprecedented size."

What Does the CAPE Portal Actually Cover?

This is the part most importers are missing.

The CAPE portal, if and when it launches, is an administrative tool for processing refunds on entries that CBP handles through its normal systems. It is designed primarily for unliquidated entries and entries where CBP can apply corrections automatically.

It does not cover everything. Specifically:

What CAPE covers: Unliquidated entries where CBP can remove the IEEPA duty line and process a refund through ACE. This is essentially the Post Summary Correction pathway, automated at scale.

What CAPE does not cover: Entries that have already been liquidated and require a formal protest under 19 U.S.C. Section 1514. Entries where CBP denies the refund and the importer needs to escalate to the Court of International Trade. Any situation where litigation is required to enforce the refund.

For most importers who have been paying IEEPA tariffs since April 2025, a significant portion of their entries have already been liquidated. Those entries will not be handled by CAPE. They require protests, and if protests are denied, CIT litigation.

The CAPE portal is one tool. It is not the whole solution.

Why You Should Not Wait: The Employee Retention Credit Parallel

I have spent 15 years recovering refunds from federal agencies. The process has never been easy, streamlined, or timely.

The most recent comparable example is the IRS Employee Retention Credit (ERC). That was a legitimate federal refund program with clear legal authority. The IRS built a processing system for it. And some claims still took three to four years to process. The IRS paused processing entirely for months at a time, flagged claims for additional review, and changed the rules repeatedly while claims were in the pipeline.

The IEEPA tariff refund situation is more complex than the ERC, not less. The government is actively fighting refunds. The administration has appealed the CIT order. Treasury Secretary Scott Bessent has publicly said repayments could take "weeks, months, or even years." CBP has already been rejecting Post Summary Corrections and suspending protest filings.

Waiting for the CAPE portal assumes that CBP will build the system on time, that the system will work correctly, that the government will not throw up additional obstacles, and that your entries will be processed without complications. That is a lot of assumptions given what we have seen so far.

The Three Bucket Approach: Why Parallel Filing Beats Waiting

At Tariff Refund Solutions, we pursue every IEEPA refund through three parallel pathways. We call them the three buckets.

Bucket 1: Post Summary Corrections (for unliquidated entries). We prepare corrected entry data and coordinate the PSC package via ACE before the 300-day window closes. If the CAPE portal launches and works, this is the bucket it covers. If it does not launch on time, we have already filed.

Bucket 2: CBP Protests (for liquidated entries). We draft and file formal protests under 19 U.S.C. Section 1514 on every eligible entry. The CAPE portal does not handle this. The 180-day deadline from liquidation is absolute, and it is running right now. Miss it and this pathway closes permanently for that entry.

Bucket 3: Court of International Trade Litigation (for all entries). We file a CIT complaint to preserve your refund position, secure similarly situated plaintiff status, and litigate through final order if needed. The CAPE portal does not handle this either. The government has stipulated it will refund similarly situated plaintiffs after final CIT orders, which means a CIT filing may be the only path that guarantees you are in line for payment.

The businesses that pursue all three buckets in parallel are covered no matter what happens. If the portal launches and works, great. If it does not, they are already in queue through the other two pathways. If the government's appeal succeeds partially, their CIT filing protects them.

The businesses that wait for the portal are betting everything on one pathway that does not exist yet.

What Happens to Our Fees If the CAPE Portal Does Launch?

Fair question. If CBP launches the CAPE portal in a reasonably timely fashion and we obtain refunds through it, our administrative fee is reduced by 50%. We built that into our engagement structure specifically because we want clients to benefit from any efficiencies the government creates.

But we are not going to tell you to sit on your hands and hope for it. Our recommendation is to pursue all three pathways now so you are in queue regardless. If the portal shows up and works, you pay less and get your money faster. If it does not, you are protected.

What Should You Do Right Now?

Do not wait for the CAPE portal. Here is what to do instead:

Check your ACE account status. The CAPE portal will run inside ACE. If you do not have an ACE account, apply now. Be aware that as of late March 2026, CBP is processing applications submitted in mid-February, which means there is a five to six week backlog. If you wait until the portal launches to apply for an account, you will be even further behind.

Pull your entry data. Run an ACE report or get your CBP Form 7501 entry summaries from your customs broker. Filter for HTS codes under 9903.01.XX and 9903.02.XX to identify your IEEPA-affected entries.

Identify which entries are liquidated and which are not. This determines which pathways apply. Liquidated entries need protests filed within 180 days. Unliquidated entries need PSCs before the 300-day window closes.

Engage counsel now. A qualified attorney can analyze your full entry data, estimate your refund, file across all three pathways, and monitor deadlines so nothing falls through the cracks.

Filing now does not conflict with the CAPE portal. If the portal launches and covers some of your entries, your attorney can process those claims through it (and at Tariff Refund Solutions, at a reduced fee). But the entries that the portal does not cover, the liquidated entries, the denied protests, the CIT complaints, those need legal action that starts before the portal even exists.

The Bottom Line

The CAPE portal might be a useful tool for part of the IEEPA refund process. It is not a reason to wait. The government has given importers no reason to trust that any single process will work smoothly, on time, or without additional obstacles.

The importers who will recover the most, and recover it fastest, are the ones who file across every available pathway right now. If you have been waiting for the portal to "figure this out," the time to stop waiting is today.

Early action protects your claim. Waiting costs you options.