UPDATE: On Monday, April 20, U.S. Customs and Border Protection launched the online portal for businesses to claim tariff refunds.


CBP has called the system rollout, which will occur in phases, a “Consolidated Administration and Processing of Entries.” CAPE incorporates ACE software to consolidate the computing required to calculate and issue refunds for the tariffs (including interest) issued under the International Emergency Economic Powers Act, which were deemed illegal.

  • Around 80% of IEEPA entries are eligible for electronic refunds.

Below is an (extremely) reduced timeline of recent events regarding tariff refunds:

  • In February, SCOTUS retroactively ruled the president did not have authority to impose global tariffs, which he had applied for much of 2025. The ruling stated that billions of dollars in refunds were now owed to importers.
  • When ordered to issue refunds, CBP claimed that it was incapable of complying with such an unprecedented request and needed time to develop an “Automated Commercial Environment” system to make up for its lack of manpower.
  • Now, the beginning stages of that system are underway.
[The April 20 rollout phase] will be limited to certain unliquidated entries and certain entries within 80 days of liquidation.”

U.S. Border and Customs Protection

Applications are deemed eligible for a refund under Phase 1 of CAPE, according to reporting from Law360’s Anna Scott Farrell, if they meet the following criteria:

  • The entry includes dutiable IEEPA HTS Chapter 99 codes.
  • The entry is either unliquidated, or liquidated within the last 80 days.
  • The entry is not flagged for reconciliation, covered by an open protest, part of a drawback claim, more than 80 days past liquidation, or subject to pending AD/CVD liquidation instructions.

The federal government has until June 6 to file an appeal of the tariffs refund ruling.

ACE Portal Required To Receive A Refund

While this technology is expected to vastly expedite the process of issuing refunds, which likely would have taken years if performed manually, it will require branded merchandise importers to apply through the proper systems.

  • Importers need an ACE portal account and will have to use it to apply for their tariff refund, according to CBP. They will also need to provide the ACE portal account with their bank account information in order to process the refund.
  • They will submit CAPE declarations through the ACE portal.
  • Upon accepting the declaration, the CAPE software can calculate what the duty would have been without the IEEPA tariff then determine a refund with applicable interest.


Unless a review of the specific request is required, importers should assume that valid IEEPA refunds will generally be issued within 60-90 days, according to CBP. The refund process include following four steps:

  • 1. Eligibility Review
  • 2. CAPE Filing
  • 3. CBP Review and Processing
  • 4. Refund Issuance


The agency expects this process to “efficiently process refunds,” though their confidence will be tested on as the refunds come in by the hundreds, if not thousands, of applications come pouring in.


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Importers and authorized brokers should anticipate that valid IEEPA refunds will generally be issued within 60-90 days following acceptance of CAPE, unless a compliance concern requires further CBP review.

Tariffs Are Not Off The Agenda

Meanwhile, the Trump administration is actively pursuing other tariff avenues:


With the Association’s Legislative Education and Action Day coming up April 20-April 21, PPAI will continue to advocate for predictable and balanced trade frameworks that support U.S. decoration, logistics and distribution jobs, says Alok Bhat, market economist and PPAI’s research and public affairs lead.

“In coordination with our lobbying partner, Thorn Run Partners, we are reinforcing Capitol Hill messaging that trade predictability protects American jobs across decoration, logistics and distribution,” Bhat says, “and we are closely monitoring any congressional action related to tariff authority.”