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CAPE Phase 1 Now Live — CBP has approved $35B+ in IEEPA tariff refunds. Phase 1 covers only certain entries. Check your eligibility →

IEEPA Tariff Refund Services · CAPE Filing Specialists

The duties you paid are refundable. We get them back.

On Feb. 20, 2026, the Supreme Court ruled IEEPA tariffs unlawful. U.S. Customs and Border Protection now owes American importers up to $166 billion in tariff refunds — but you only get yours if you file correctly through CAPE. Cardinal Customs handles every step. No upfront fees.

Check My Refund Eligibility Call (347) 670-3777
$166B+ Total IEEPA duties refundable to U.S. importers
60–90 days Typical refund timeline after CAPE acceptance
0% Upfront cost — contingency-based pricing

— Our Core Service

IEEPA Tariff Refunds. Filed through CAPE. Done right.

If your business paid IEEPA tariffs on imports between April 5, 2025 and February 24, 2026 — including the so-called "fentanyl tariffs" on Canada, Mexico, and China, or the "reciprocal tariffs" applied to most other countries — you are very likely owed a refund, plus statutory interest.

CBP launched Phase 1 of the Consolidated Administration and Processing of Entries (CAPE) tool on April 20, 2026. It is the only mechanism to recover IEEPA duties. The submission itself is technically straightforward — a CSV upload of entry numbers — but successful claims depend entirely on correct entry identification, ACE Portal access, ACH refund enrollment, and clean documentation. Rejections are common, and once a CAPE Declaration is accepted, it cannot be amended.

Cardinal Customs files CAPE Declarations on behalf of clients, monitors every entry through liquidation, and follows up on any CBP information requests. You sit back; the refund hits your account.

$35.5B
In IEEPA refunds approved by CBP as of mid-May 2026, including statutory interest.
87,000+
Refund requests already accepted by CBP, covering 15M+ duty payments.
53M
Total IEEPA entries across approximately 330,000 importers nationwide.
180 days
Protest window for liquidated entries — Phase 2 territory.
Start My CAPE Claim

— Beyond IEEPA

Every other pathway to a duty refund — handled under one roof.

IEEPA isn't the only place importers are leaving money behind. The Supreme Court's ruling did not affect Section 232, Section 301, or other duty programs — but most importers still have unclaimed refunds across these. Cardinal Customs audits your full duty footprint.

— 01

Section 301 Exclusions & Refunds

Identify entries eligible for granted or reinstated Section 301 (China) exclusions. We file protests and Post Summary Corrections within statutory windows to recover tariff overpayments.

— 02

HTS Classification Reviews

The single largest source of duty overpayment. We perform line-by-line entry summary audits and file 19 USC 1520(d) corrections and 19 USC 1514 protests where HTS misclassification is identified.

— 03

Duty Drawback Programs

Recover up to 99% of duties on goods later exported, destroyed, or used in U.S. manufacturing. We design and administer your duty drawback program end-to-end, including accelerated payment.

— 04

Antidumping & Countervailing Duty

Scope rulings, annual administrative reviews, and refund claims when final rates are lower than cash deposits. We coordinate directly with the U.S. Department of Commerce and CBP.

— 05

First Sale for Export Valuation

Lower your dutiable value by declaring the first sale between manufacturer and middleman rather than the final sale to you. We document and defend the structure under CBP scrutiny.

— 06

USMCA & FTA Post-Import Claims

Retroactive preference claims under 19 USC 1520(d) for USMCA, KORUS, CAFTA-DR and other free trade agreements when goods qualified but the preference wasn't claimed at entry.

— How It Works

Four steps. No risk. You only pay from the refund.

Most engagements move from discovery to filed claim in under 30 days. You receive a full exposure estimate before we file anything — and you pay nothing unless we recover duties.

— Step 01

Discovery Call

30-minute call to understand your import volume, suppliers, and which tariff codes hit your entries. We give you an honest read on your refund potential.

— Step 02

Entry & ACE Audit

With your authorization, we pull ACE Portal data, verify ACH refund enrollment, and produce an Exposure Memo — IEEPA-eligible entries, Section 301 opportunities, and misclassifications flagged.

— Step 03

Filing & Defense

We file your CAPE Declarations, PSCs, Protests, and Drawback claims. We respond to CBP information requests, monitor liquidation, and chase down any rejections.

— Step 04

You Get Paid

CBP issues refunds via ACH directly to your bank account, typically 60–90 days from acceptance. Our contingency fee is deducted from recovery — never billed upfront.

— Step-by-Step Guide

How to file your IEEPA tariff refund. Yourself.

We're not going to hide the process behind a contact form. If you have the time, the entry data, and the patience for CBP's validation rules, you can file your own CAPE Declaration. Below is the complete process — the same one we run for clients, written so you can follow it end to end.

If, after reading it, you decide you'd rather hand it off — that's why we're here too. Either path works. Skip to scheduling →

— Before You Start · Two Gates That Stop Most Filers

Gate 1

ACE Portal Access

CAPE lives inside CBP's Automated Commercial Environment (ACE) Secure Data Portal. The Importer of Record (IOR) — or the licensed customs broker that originally filed the entries — needs an active sub-account with portal credentials. No portal access means no filing. CAPE cannot be submitted via ABI or EDI; it must be done through the ACE web portal.

Gate 2

ACH Refund Enrollment

CBP stopped issuing paper refund checks on February 6, 2026. Every refund is now ACH. Banking details must be entered under the Importer sub-account in the ACE Portal — this is a manual setup step that does not happen automatically. CBP will hold your refund indefinitely if ACH details are missing or stale.

— The Filing Process

  1. Confirm Your Entries Qualify for Phase 1

    CAPE Phase 1 is intentionally narrow. To qualify, an entry must (a) have at least one dutiable IEEPA Chapter 99 HTS code on the entry summary, and (b) be either unliquidated, or within 80 days of its liquidation date (the 90-day voluntary reliquidation window under 19 USC §1501).

    Phase 1 does NOT cover: entries fully liquidated more than 80 days ago, Type 09 Reconciliation entries, Type 47 Drawback entries, entries with active AD/CVD liquidation instructions, Type 08 Duty Deferral, or Type 23 Temporary Importation under Bond. Those are deferred to later phases or require a protest under 19 USC §1514.

    Tip: Pull your full IEEPA entry list from ACE itself — the ES-003 report is the source of truth. Don't rely solely on your broker's records; brokers occasionally miss entries filed by other brokers under the same IOR.

  2. Verify ACH Refund Banking in ACE

    Log into the ACE Portal, navigate to your Importer sub-account, and confirm a current ACH refund bank account is on file. If you've never enrolled, follow CBP's "Enrolling in ACH Refunds" workflow — you'll need your routing number, account number, and bank contact information.

    If you want refunds sent to a different party (a parent company, a designated representative), file CBP Form 4811 (Special Address Notification). Important caveat: Form 4811 only redirects the payment destination — it does not transfer legal ownership of the refund.

    Tip: Non-resident importers face an extra hurdle here — ACH-to-foreign-bank rejections are one of the most reported issues. Use a U.S. correspondent bank account if you have one.

  3. Download the CAPE Upload Template

    Inside the ACE Portal, find the new CAPE tab (visible in Importer, Organizational Broker, and Filer sub-account views). Click the CAPE Upload Template link to download the template — it's an Excel file with a single column labeled Entry Number in Column A, Row 1.

    Do not modify the template structure. Do not add columns. Do not rename headers. The validator rejects any deviation from the expected format.

  4. Populate the Template With Entry Numbers Only

    Paste your qualifying entry numbers down Column A, one per row. Entry numbers only. No HTS codes, no duty amounts, no port codes, no dates — just the entry number itself. CBP recalculates everything else from its own records.

    Each CAPE Declaration is capped at 9,999 entries. If you have more, split into multiple declarations. Brokers filing on behalf of multiple IORs can include entries across IORs in a single declaration, provided the broker was the original filer on each.

    Tip: Duplicates are fatal. An entry can appear on exactly one accepted CAPE Declaration — ever. If you submit a duplicate (within the same declaration or against any previously accepted one), the entire entry gets rejected, not just the duplicate row. Run a deduplication pass before you upload.

  5. Save as CSV and Upload

    Save the populated template as a CSV file. The CBP filename convention is ACEP_CapeEntryNumberUploadTemplate.csv. Return to the CAPE tab, click the Upload button, select your CSV, and acknowledge the filer certification (you're attesting you're legally authorized to file).

    Once submitted, ACE runs two rounds of validation: first at the declaration level (file format, importer identity, certification, ACH status), then at the entry level (each entry's eligibility, liquidation status, IEEPA Chapter 99 presence, duplicate check). The portal shows a progress bar; valid entries proceed, invalid ones are flagged with a reason code.

  6. Track Acceptance and Liquidation

    Accepted declarations receive a unique CAPE claim number. Track status via the REV-615 CAPE Refunds Trade Report inside your ACE Portal.

    What happens next, automatically:

    • Unliquidated entries are scheduled to liquidate ~45 days after declaration acceptance.
    • Entries already liquidated within the 80-day window are reliquidated the next business day.
    • Suspended, extended, or under-review entries keep their existing liquidation status and pay at final liquidation.

    Critical: Once a CAPE Declaration is accepted, it cannot be amended. Entries left off — discovered later — must go on a brand-new declaration. Plan your batches carefully.

  7. Receive Your Refund via ACH

    CBP issues consolidated refunds — one lump sum per IOR per liquidation date, not entry by entry — via ACH within 60 to 90 days of declaration acceptance, unless a compliance review extends the timeline.

    Interest is automatically calculated under 19 CFR §24.36 from the date each duty was originally paid: 7% for individuals, 6% for corporations, compounded as set by the IRS quarterly rate. You don't need to claim it separately.

    For CAPE technical questions, CBP staffs IEEPARefunds@cbp.dhs.gov. For general inquiries, traderelations@cbp.dhs.gov.

Sound like a lot? It is.

If you have 10 or fewer entries and a calm afternoon, DIY is genuinely feasible. If you have hundreds — across multiple brokers, ports, and liquidation dates — the rejection patterns above eat weeks of staff time. We file CAPE Declarations every day. Nothing rejects, nothing delays, nothing leaks. You get the refund and we get a percentage. Until then, you owe nothing.

Hand It Off Instead

— Why Choose Cardinal Customs

Built for importers who don't have time to learn customs law.

  • No win, no fee.

    Pure contingency. If we don't recover duties, you owe nothing — not even a discovery fee. We only win when you do.

  • We know CAPE inside out.

    From ACH enrollment to CSV validation to Form 4811 notify-party setup, we've run claims through the new system. We avoid the rejection patterns that delay refunds by months.

  • Zero disruption to your team.

    We work directly with ACE data and your customs broker. Your operations and finance teams give us about two hours total. That's it.

  • Audit-ready documentation.

    Every filing is backed by a defensible legal memo and source documents. If CBP follows up, we respond. Your refund is protected through final liquidation.

  • Phase 2 ready, today.

    While Phase 1 catches the easy wins, we're already preparing protest-based filings for older liquidated entries and reconciliation work that will unlock under CAPE Phases 2 and 3.

— Common Questions

What importers ask us first.

Don't see your question? Book a free consultation — we'll give you a straight answer in 30 minutes or less.

Am I eligible for an IEEPA tariff refund?

If you imported into the U.S. between April 5, 2025 and Feb. 24, 2026 and your entry summaries include duties paid under IEEPA (Chapter 99 HTS provisions), you're almost certainly owed money. We confirm in the discovery call before any commitment.

What is CAPE and how does it work?

CAPE stands for Consolidated Administration and Processing of Entries. It is CBP's electronic refund system launched April 20, 2026, inside the ACE Portal. Importers or their authorized brokers submit a CSV file (a CAPE Declaration) listing eligible entry numbers. CBP recalculates duties, liquidates the entries, and issues refunds via ACH within 60–90 days, with statutory interest.

What if my entries have already liquidated?

Phase 1 covers unliquidated entries and entries within 80 days of liquidation. Older liquidated entries require a different path — protests under 19 USC 1514, or waiting for Phase 2 of CAPE. We file the right vehicle for each entry in your portfolio.

Can't my customs broker do this for free?

Some brokers will file Phase 1 CAPE Declarations for entries they originally cleared. But brokers rarely audit for Section 301 exclusions, classification errors, drawback, or FTA opportunities. We do all of it, and we own the outcome end-to-end.

Do I get interest on my refund?

Yes. IEEPA refunds issued through CAPE include statutory interest accrued from the date the duty was paid. CBP calculates and adds this automatically — you don't have to claim it separately.

Why not just sell my claim to a hedge fund?

Some firms are buying claims for instant cash at a steep discount — typically 60–75 cents on the dollar. If you need liquidity immediately, that's an option. If you can wait 60–90 days, working with us recovers 100% (minus our contingency), plus interest.

What does this cost?

Nothing upfront. Our fee is a percentage of recovered duties, deducted from refunds when they arrive. The exact rate depends on engagement complexity and total recovery volume — we quote it before any work begins.

Find out what you're owed.

Book a free 30-minute call with Cardinal Customs. We'll review your import footprint, estimate your IEEPA refund window, and flag other duty recovery opportunities. No commitment, no upfront fees.

Schedule a Free Call

— Or call us directly

(347) 670-3777

Speak with a recovery specialist. No automated menus, no gatekeeping.

Mon–Fri · 8:30 AM – 6:00 PM ET