If you’ve been trying to understand how IEEPA tariff refunds will actually work, you’ve probably seen two acronyms floating around: ACE and CAPE. They sound similar. They’re both CBP systems. And most coverage treats them interchangeably, which creates confusion at exactly the wrong time.
They’re not the same thing. ACE is the existing system that holds all of your import data. CAPE is the new module being built inside ACE specifically to process IEEPA refund claims. Understanding how they relate — and how data flows between them — gives you a real advantage when it comes time to file.
Here’s the breakdown.
What ACE is and what it does
ACE stands for Automated Commercial Environment. It’s CBP’s primary system for processing all U.S. imports and exports. If you’ve imported anything into the United States in the last decade, your data lives in ACE.
ACE handles:
- Entry filing — your customs broker submits entry summaries through ACE when your goods arrive
- Tariff classification — HTS codes, duty rates, and tariff provisions are recorded in ACE at the line level
- Duty collection — CBP assesses and collects duties through ACE, including IEEPA surcharges under HTS headings 9903.01 and 9903.02
- Liquidation — the process of finalizing an entry and making it “official” happens in ACE, typically about 314 days after filing
- Compliance and enforcement — audits, penalties, and compliance actions are tracked in ACE
- Reporting — the ES-003 Entry Summary Details report and other reports are generated from ACE data
Think of ACE as the master database. Every entry, every line item, every duty payment, every liquidation action — it’s all in ACE. The system has been operational since 2011 (replacing the earlier ACS system) and processes over 30 million entry summaries per year.
ACE was not designed for mass refund processing. It handles individual post-summary corrections and protests just fine, but it doesn’t have a mechanism for bulk claim intake, automated validation against refund-specific criteria, or mass payment processing. That’s why CBP is building CAPE.
What CAPE is and what it does
CAPE stands for Claims Adjudication and Processing Engine. It’s a new software module being constructed within the ACE environment specifically to handle IEEPA tariff refund claims. CBP started building CAPE after the CIT’s March 4 order directed universal refunds following the Supreme Court’s ruling.
CAPE handles:
- Claim intake — a web-based portal where importers or their representatives submit refund declarations
- Automated validation — cross-references claim data against ACE records to verify eligibility, HTS codes, and duty amounts
- Mass processing — bulk adjudication of validated claims without manual intervention
- Manual review routing — flags discrepant claims for CBP officer review
- Interest calculation — computes statutory interest under 19 U.S.C. Section 1505(c) for each approved claim
- Refund disbursement — generates payment instructions for ACH transfer
CAPE is purpose-built for the IEEPA refund event. It’s not a general-purpose refund system — it’s designed to handle one specific type of claim (IEEPA tariff overpayments during the Feb 4, 2025 to Feb 24, 2026 window) at massive scale (330,000+ importers, 53 million entry lines).
How they work together: the data flow
Here’s where it gets practical. When you file a claim through CAPE, here’s what happens behind the scenes:
Step 1: You submit your claim through the CAPE portal
You (or your broker) log into the CAPE claim portal — which is accessed through the ACE system — and submit a refund declaration. The declaration includes your importer of record number, the entry summary numbers you’re claiming on, the HTS codes (9903.01 or 9903.02), and the duty amounts you’re claiming as refundable.
Step 2: CAPE queries ACE for your entry data
This is the critical integration point. CAPE doesn’t take your word for it. It pulls your original entry data directly from ACE and compares it against your claim. For each entry line you’re claiming:
- Does the entry exist in ACE under your IOR number?
- Was it filed during the IEEPA coverage period?
- Does the HTS code match what was originally filed?
- Does the duty amount match what ACE shows as paid?
- What’s the current liquidation status?
- Are there any pending compliance actions?
This cross-referencing is automatic and happens in real time. If everything matches, the claim moves to automated processing. If there are discrepancies, the claim routes to manual review.
Step 3: CAPE processes the claim using ACE data
For approved claims, CAPE calculates the refund amount based on ACE’s duty records, computes statutory interest from the overpayment date, and generates a reliquidation action in ACE. The refund is then processed through ACE’s existing payment infrastructure and disbursed via ACH.
Step 4: ACE records the refund
Once the refund is disbursed, ACE updates the entry record to reflect the reliquidation and refund. The entry status changes from “liquidated” to “reliquidated” with the refund amount and date recorded. This creates a permanent audit trail within ACE.
The key insight: CAPE doesn’t replace ACE. It sits on top of ACE. All of the underlying data — your entries, your duties, your liquidation history — remains in ACE. CAPE is just the processing layer that reads that data, validates claims against it, and writes refund actions back to it.
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Why ACE data quality is your single biggest risk factor
Because CAPE validates claims against ACE data, the quality of your ACE records directly determines how your claim is processed. If ACE shows exactly what you’re claiming, automated processing. If ACE shows something different, manual review — and months of delay.
Here are the most common ACE data quality issues that could affect your CAPE claim:
Amended entries
If your broker filed a post-summary correction on an entry after the original filing, ACE may show the amended data rather than the original. If the amendment changed the HTS code or duty amount, your CAPE claim needs to reference the current ACE data, not your original broker invoice.
Multiple HTS codes on a single entry
Many entry summaries contain lines with IEEPA tariff codes (9903.01, 9903.02) alongside lines with non-IEEPA codes (regular duty rates, Section 301 under 9903.88, Section 232 under 9903.80). Your CAPE claim should only include the IEEPA lines. If you accidentally include non-IEEPA lines, the claim will be flagged.
Liquidation timing discrepancies
ACE records the liquidation date for each entry, but there can be a lag between when liquidation occurs and when the status updates in ACE reports. If you check liquidation status today and it shows “unliquidated,” but by the time CAPE processes your claim it’s been liquidated, the processing path may change. This is why mapping your liquidation status and filing protective protests on entries approaching liquidation is important.
Duty amounts that include broker processing fees
ACE records the actual duty amount assessed by CBP. Your broker’s invoice may include processing fees, merchandise processing fees (MPF), or harbor maintenance fees (HMF) bundled together. Your CAPE claim should reference only the IEEPA duty amount as recorded in ACE, not your total payment to the broker. The ES-003 report breaks this out at the line level.
Entries filed under a different IOR number
If your company changed its IOR number during the IEEPA period (due to a corporate restructuring, merger, or broker change), you may have entries in ACE under different IOR numbers. CAPE processes claims by IOR, so you’ll need to file separate claims for each IOR number — or work with CBP to consolidate the records first.
How to check your ACE data before CAPE opens
The best time to identify and fix ACE data quality issues is now — before the portal opens. Here’s how:
Pull your ES-003 report
The ES-003 Entry Summary Details report is the standard ACE report that shows your entry data at the line level. Export it for the full IEEPA period (February 4, 2025, through February 24, 2026) and review every line.
If you have direct ACE portal access, you can pull this yourself. If not, your customs broker can generate it. Either way, this report is the single most important document for your IEEPA refund preparation.
Reconcile against your internal records
Compare the ES-003 data against your accounts payable records, broker invoices, and shipping documents. Look for:
- Entry summary numbers that appear in your records but not in the ES-003 (possible missed entries)
- Duty amounts that don’t match between ACE and your invoices
- HTS codes that differ from what you expected
- Entries you believe should have IEEPA codes but don’t show 9903.01 or 9903.02
Check liquidation status
For each entry in your ES-003, determine whether it’s unliquidated, liquidated within the 180-day protest window, or liquidated beyond the window. This determines which recovery path applies to each entry and whether you need to file protective protests before CAPE opens.
Resolve discrepancies with your broker
If you find mismatches between your records and ACE data, work with your broker to investigate and resolve them. Your broker can file post-summary corrections for unliquidated entries to fix HTS codes or duty amounts. For liquidated entries, discrepancies may need to be addressed through the protest or CAPE claim process.
The practical difference for importers
Understanding the ACE-CAPE relationship has practical implications for your refund strategy:
Your ACE data already exists. You don’t need to “create” data for CAPE. The entry information is already in ACE from when your goods were originally imported. Your job is to validate that the existing ACE data is correct and complete, not to generate new documentation.
Your broker is your ACE expert. Your customs broker works in ACE every day. They can pull reports, check liquidation status, file corrections, and help you understand what ACE shows for your entries. If you’re not sure about your ACE data quality, your broker is the first call to make.
CAPE inherits ACE’s limitations. ACE data isn’t perfect. Entries can be mis-coded, duty amounts can be inaccurate, and liquidation statuses can be delayed. If ACE has bad data for your entries, CAPE will see that bad data when it validates your claim. Fix ACE issues now so they don’t become CAPE problems later.
ACE access is your preparation tool. While CAPE isn’t live yet, ACE is. You can log in today, pull reports, check statuses, and identify issues. Every hour you spend in ACE today is an hour you don’t spend troubleshooting CAPE rejections after the portal opens.
What ACE can’t tell you (and what you need separately)
ACE contains your entry data, but it doesn’t tell you everything you need for a complete IEEPA recovery strategy. Specifically, ACE doesn’t provide:
- Statutory interest calculations — ACE shows duty amounts and dates, but doesn’t calculate the interest you’re owed under 19 U.S.C. Section 1505(c)
- Recovery path recommendations — ACE shows liquidation status, but doesn’t map each entry to the optimal recovery mechanism (PSC, protest, CIT, or claim assignment)
- Deadline tracking — ACE shows liquidation dates, but doesn’t flag entries approaching their 180-day protest window
- Total exposure calculation — ACE shows individual entry lines, but doesn’t aggregate your total IEEPA refund exposure across all entries
- Filing readiness assessment — ACE holds the raw data, but doesn’t evaluate whether that data is clean enough for automated CAPE processing
An Impact Assessment fills these gaps. It takes your ACE data as input and produces a complete filing-ready package: validated entries, calculated refund amounts with interest, liquidation status mapping, deadline tracking, recovery path recommendations, and data quality flags. It’s the bridge between what ACE holds and what CAPE will need.
Frequently asked questions about ACE and CAPE
Can I use ACE to file my IEEPA refund claim right now?
No. ACE currently supports individual Post-Summary Corrections (for unliquidated entries) and formal protests (for liquidated entries), but it doesn’t have a bulk IEEPA refund claim mechanism. That’s what CAPE is being built for. You can and should use ACE now to pull your ES-003 data and check liquidation statuses, but you’ll need to wait for the CAPE portal to file bulk refund declarations.
Will I need a separate login for CAPE?
No. CAPE is built within ACE, so your existing ACE portal credentials will work. If you access ACE through your customs broker, your broker will use their existing ACE login to access the CAPE portal on your behalf.
Does CAPE replace the protest process?
No. CAPE is a new filing mechanism specifically for IEEPA refund declarations. The existing protest process under 19 U.S.C. Section 1514 remains available and, in many cases, should be used in parallel with CAPE preparation. Filing a protective protest on a liquidated entry preserves your rights regardless of CAPE’s timeline.
What if ACE has wrong data for my entries?
Fix it before CAPE opens. Work with your broker to file corrections through ACE. If entries have incorrect HTS codes, wrong duty amounts, or missing data, those errors will cause CAPE to flag your claim for manual review. The time to resolve ACE data quality issues is now, not after you’ve filed a CAPE claim and it’s been rejected.
Can CAPE process refunds for entries filed before ACE existed?
The IEEPA tariffs were in effect from February 4, 2025, to February 24, 2026. All entries during this period were filed through ACE (the legacy ACS system was decommissioned years ago). So all IEEPA-eligible entries are in ACE, and CAPE can access them.
What happens to my CAPE claim if my company is acquired or merges?
CAPE processes claims by Importer of Record number. If your company’s IOR changes due to a merger or acquisition, you may need to file claims under both the old and new IOR numbers. Work with your broker and legal counsel to ensure continuity of claims across corporate changes.
The bottom line
ACE is the foundation. CAPE is the processing layer. Your ACE data quality determines your CAPE processing speed. The importers who understand this relationship — and invest time now in validating their ACE data — will be the first to receive refunds when CAPE goes live.
Don’t wait for CAPE to discover that your ACE data has problems. Discover them now, fix them now, and be ready to file a clean claim on day one.
