May 18, 2026 CAPE is Here – How to Claim Your Tariff Refund

Here are the key considerations for manufacturing and supply chain businesses as they look to claim their IEEPA refunds.

By Charles Clevenger, Principal, UHY

Key Takeaways

• U.S. Customs and Border Protection (CBP) Consolidated Administration and Processing of Entries (CAPE) tool is well underway and organizations need to know the ins-and-outs.
• Organizations seeking refunds need to make sure they are “refund ready” by making sure documentation is prepared and Automated Commercial Environment (ACE) accounts are all fully operational with accurate and updated information.
• The refund process for importers of record (IORs) and non-IORs is different and organizations need to understand the nuances.
• This is only Phase 1 of the refund process so organizations need to remain on their toes for future next steps.

Now that the tariff refund process is underway in the U.S. how do we get our money back?

Arguably, nothing has created more operational complexity for businesses and their decision makers over the last year than tariffs. So, the fact that organizations now could potentially claw back a portion of the estimated $175 billion in refunds following the Supreme Court’s strike down of the International Emergency Economic Powers Act (IEEPA) tariffs has been music to many business owners’ ears. But recovering funds is easier said than done, and for some the process is still unclear.

While on the surface, the fact that the refund process opened as of April 20, 2026, is potentially great news for importers, businesses now face another wave of uncertainty regarding what is refundable, what is needed to file, and what the process actually looks like, among other factors.

CBP launches CAPE. What is it?

After nearly two years of managing costs and tightening budgets, the launch of U.S. Customs and Border Protection (CBP) Consolidated Administration and Processing of Entries (CAPE) tool in the Automated Commercial Environment (ACE) Secure Data Portal on April 20, provided welcome clarity. This tool, billed as “Phase 1” in the refund process, was launched to help streamline the refund process by giving authorized customs brokers and importers an electronic avenue to submit claims.

1. How does CAPE work?

One of the biggest benefits of CAPE is that it allows organizations to navigate the refund process in a more consolidated way. Through the platform, importers of record (IORs) have their refunds of IEEPA duties, including interest, consolidated rather than split across an entry-by-entry basis. This reduces burdens for organizations that may have multiple entries.

According to CBP, the CAPE process works as follows:

• The IOR, or an authorized customs broker, submits a CAPE Declaration in the ACE Portal
• CBP removes the applicable IEEPA Harmonized Tariff Schedule number
• CBP recalculates the duties due without the IEEPA duty
• The entry is updated to a new version for review
• CBP liquidates or reliquidates the entry
• Refunds are then consolidated by IOR, or by the party designated through CBP Form 4811, and by liquidation date

It is important to note that while CAPE is a helpful initial step, it does have restrictions in terms of what is covered.  Phase 1 is limited and applies only to certain unliquidated entries and certain entries within 80 days of liquidation. That said, it is expected that more complicated claims will be addressed in future phases.

2. What are the requirements for CAPE refunds?

Irrespective of eligibility for Phase 1, it is important that organizations familiarize themselves with what it means to be “refund ready” so they can navigate the CAPE process more efficiently and avoid any procedural snags. This begins with making sure that you have your ACE account in order as soon as possible, including:

1. Establish an ACE Portal account
2. Provide refund banking information so CBP can seamlessly issue electronic refunds
3. Submit a CAPE declaration through the ACE Portal

Once IORs confirm that they have ACE Portal access and that their banking information and associated declarations are correct, they ensure that they align with their customs brokers and have a firm grasp of potentially eligible entries, allowing them to claim all appropriate refunds.

3. What if we are not an IOR?

Phase 1 strictly addresses a subset of entries relating specifically to IORs and does not apply to businesses that are not listed as IORs. These businesses face a different path going forward but nonetheless should actively engage in building refund foundations and preparing for the claims process in future phases. This includes:

• Identify the IOR for impacted shipments and confirm if they are pursuing refund claims themselves
• Audit documentation for additional costs, who absorbed them and be prepared to substantiate those claims and work collaboratively with IOR to recoup costs
• Review existing contracts for “tariff recovery clauses”

Looking ahead

The launch of CAPE has certainly been welcome news for many businesses. And whether you are an IOR that is eligible for Phase 1 or a non-IOR, preparation is pivotal to securing tariff refunds. IORs that have portal access and all of their administrative details confirmed will be far more ready to quickly reclaim funds. Non-IORs need to make sure that they have a complete view of impacted shipments so they can work with IORs and be prepared for future refund opportunities. With these foundations in place, organizations can put themselves in the best position to capture refunds and navigate any future refund questions that may arise.

About the Author:
Charles Clevenger is a principal at UHY, providing operational excellence solutions that strengthen and transform organizations.  His specialties include complex supply chain, procurement strategy and structure, operations management, total value management analysis, and solutions. He also has significant experience collaboratively integrating these areas into the overall business to optimize performance and financial results.

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