U.S. Customs and Border Protection has opened Phase 1 of the IEEPA refund process through CAPE Declarations, but the filing window starting 20 April 2026 comes with strict technical requirements. Importers and brokers who skip the groundwork will face delays or outright rejection.
CBP has made the process clearer, but clearer does not mean easy. Two barriers control access: ACE Portal permissions and ACH banking enrolment. Miss either one, and your refund claim stops before it starts.
ACE Portal Access: Who Can File and Who Cannot
Only the importer of record or the licensed customs broker who filed the original entries can submit a CAPE Declaration. No exceptions. If your company uses a broker, confirm who holds the portal login and whether that broker still operates under the same licence.
Portal access requires active credentials tied to the correct importer of record. Importers who changed brokers, merged with another company, or restructured since the original entries were filed must resolve ownership and access issues before the April deadline. CBP will not accept filings from unauthorised parties.
Brokers managing multiple clients can file a single CAPE Declaration covering up to 9,999 entries across different importers of record. This batch filing option speeds up processing but requires meticulous entry verification. One rejected entry in a batch will be dropped, and the importer must refile it separately.
ACH Banking Enrolment: No Account Equals No Refund
CBP cannot issue refunds without valid ACH banking details on file. Even if your CAPE Declaration is approved, the refund will not be delivered if banking information is missing or incorrect. Worse, interest stops accruing once CBP approves the refund, even if the payment cannot be completed.
As one customs expert noted, “if CBP approves the refund but cannot deliver it because banking details were never provided or fixed, interest does not keep piling up while that problem sits unresolved.”
Importers must verify that their ACE Portal account includes current ACH enrolment. Companies that changed banks, updated account numbers, or restructured financial operations since 2018 need to update their details immediately. Freight professionals managing compliance for multiple clients should audit banking records across all importers of record before the filing window opens.
Phase 1 Coverage: What Qualifies and What Does Not
Phase 1 covers approximately 63% of impacted entries, but the eligibility rules are narrow. Only unliquidated entries and entries that liquidated within the prior 80 days can be included. CBP excludes several categories outright:
- Reconciliation entries
- Entries with open protests
- Drawback entries
- Antidumping and countervailing duty entries pending liquidation
Importers with mixed entry types must separate eligible and ineligible claims. Filing a CAPE Declaration with excluded entries will result in partial rejection, and the dropped entries must be refiled later. CBP’s CAPE claim portal is now 85% complete and in testing, but the system will not flag ineligible entries before submission.
No Amendments After Filing: Get It Right the First Time
Once CBP accepts a CAPE Declaration, it cannot be amended. Errors in entry numbers, importer details, or refund amounts are permanent. Importers must review every line before submission. Rejected entries can be refiled, but the delay resets the 60 to 90 day refund timeline.
Customs brokers handling batch filings for multiple clients should implement a two-stage verification process: one review by the operations team and a second review by the importer of record before submission. The cost of fixing a filing error after acceptance is measured in months, not days.
Where to Direct Questions and Filing Errors
CBP has separated policy questions from technical support. Policy questions about IEEPA refund eligibility, entry qualifications, or Phase 1 coverage should go to IEEPARefunds@cbp.dhs.gov. Filing errors, ACE Portal access issues, or CAPE Declaration submission problems should be directed to your CBP client representative or the ACE Help Desk.
Importers without an assigned client representative should contact the ACE Help Desk before the April filing window opens. Waiting until 20 April to resolve portal access or banking issues guarantees delays.
How Independent Forwarders Should Prepare Clients
Independent freight forwarders managing U.S. import clients should audit IEEPA refund eligibility now. Phase 1 covers 63% of impacted entries, but only if importers complete the technical setup before April. Forwarders who wait until the filing window opens will lose time and credibility.
Start with a client-by-client review of ACE Portal access and ACH banking enrolment. Confirm that the importer of record or the original customs broker holds active portal credentials. Verify that banking details match current accounts. Flag entries that fall outside Phase 1 eligibility and set expectations for future filing phases.
Forwarders handling complex multi-leg shipments or door-to-door services should cross-reference entry liquidation dates against the 80-day Phase 1 window. Entries that liquidated earlier may qualify for later phases, but CBP has not yet published Phase 2 timelines or eligibility rules.
Frequently Asked Questions
What happens if my CAPE Declaration is accepted but my banking details are wrong?
CBP will approve the refund but cannot deliver it. Interest stops accruing once CBP approves the claim, even if payment fails. You must update your ACH banking enrolment in the ACE Portal and contact CBP to reissue the refund, which adds weeks or months to the process.
Can I file a CAPE Declaration for entries that liquidated more than 80 days ago?
No. Phase 1 covers only unliquidated entries and entries that liquidated within the prior 80 days. Entries that liquidated earlier may qualify for future phases, but CBP has not yet announced Phase 2 timelines or eligibility criteria.
Can I amend a CAPE Declaration after CBP accepts it?
No. Accepted CAPE Declarations cannot be amended. Errors in entry numbers, importer details, or refund amounts are permanent. Rejected entries can be refiled separately, but the refund timeline resets to 60 to 90 days from the new submission date.
Who can file a CAPE Declaration on behalf of an importer?
Only the importer of record or the licensed customs broker who filed the original entries can submit a CAPE Declaration. No third parties or reassigned brokers can file unless they hold active ACE Portal credentials tied to the correct importer of record.
How long do IEEPA refunds take after CBP accepts a CAPE Declaration?
Valid refunds arrive within 60 to 90 days after CBP accepts the declaration, provided ACH banking details are correct and complete. Delays occur if banking information is missing, outdated, or incorrect.
Act Before April or Lose Months
IEEPA refunds are not automatic. Importers who miss the ACE Portal and ACH banking setup before 20 April 2026 will face rejection, delays, and lost interest. Independent forwarders managing U.S. import clients should audit eligibility and technical readiness now, not in April.
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