CAPE Portal Filing Guide: Step-by-Step for IEEPA Tariff Refunds

The CAPE portal is coming. CBP has told the Court of International Trade that the Claim Portal component is approximately 73% complete, with a target launch of mid-April 2026. When it opens, over 330,000 importers will be eligible to file claims for IEEPA tariff refunds. The importers who file first — with complete, validated data — will be processed first.

This guide covers everything you need to prepare before the portal opens and what to expect once it does. Think of it as your pre-flight checklist. When the portal goes live, you don’t want to be scrambling for data. You want to click “submit.”

What CAPE will require: the data checklist

Based on CBP’s court declarations about CAPE’s design and its integration with the existing ACE system, here’s what you’ll need for each claim submission. Note that CBP hasn’t published final portal specifications yet — this is based on what we know from court filings and the standard data elements CBP uses for entry-level processing.

Entry-level data

For every entry you’re claiming a refund on, CAPE will need:

If you don’t have all of these fields readily available, that’s exactly what the ES-003 Entry Summary Details report from ACE provides. It’s the single most important document for CAPE filing.

Importer-level data

Beyond the entry-level details, CAPE will need importer-level information:

• Importer of Record (IOR) number — your CBP-assigned importer number
• Power of Attorney — if you’re filing through a broker or representative, a valid POA must be on file with CBP
• ACH banking information — CBP will disburse refunds electronically. If you’re not enrolled in ACH, you’ll need to complete enrollment before any refund can be processed
• Contact information — email and phone for any follow-up communication from CBP

Most of this is already on file with CBP if you’re an active importer. But verify it now — outdated banking information or an expired POA could delay your refund even after your claim is approved.

Step 1: Pull your ES-003 report now

Don’t wait for the portal to open. The most important thing you can do right now is export your ES-003 Entry Summary Details report from the ACE portal for the full IEEPA coverage period: February 4, 2025, through February 24, 2026.

Here’s the process:

1. Log into the ACE portal
2. Navigate to Reports in the main menu
3. Select ES-003 Entry Summary Details
4. Set your date range: start date February 4, 2025; end date February 24, 2026
5. Select all available fields (you want the full dataset)
6. Export as CSV

If you don’t have direct ACE portal access, your customs broker can pull this report on your behalf. Most brokers are already doing this proactively for their importer clients — if yours hasn’t offered, ask. Our broker coordination guide includes a template request you can send.

The ES-003 will show you every entry summary filed during the IEEPA period, including the HTS codes at the line level. You’re looking for lines with HTS codes under headings 9903.01 (fentanyl-related IEEPA tariffs) and 9903.02 (reciprocal/Liberation Day tariffs). Only these codes are eligible for IEEPA refunds — other Chapter 99 codes like 9903.88 (Section 301) or 9903.80 (Section 232) are not covered by the Supreme Court ruling.

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Step 2: Validate your data against CBP’s records

This is where most importers either save themselves months or unknowingly set themselves up for delay. CAPE will cross-reference your claim data against CBP’s own records in ACE. If there’s a mismatch — you claim $50,000 in duties on an entry but ACE shows $47,500, or your HTS code doesn’t match what the broker originally filed — CAPE will flag the discrepancy and route your claim to manual review.

Manual review means your claim goes from the automated processing queue to a pile on a CBP officer’s desk. With 2,500 staff processing 53 million entry lines, that’s not where you want to be.

Here’s what to validate:

Duty amount reconciliation

Compare the duty amounts on your ES-003 with your own internal records (accounts payable, broker invoices, payment confirmations). Discrepancies usually come from one of three sources:

• Broker processing fees included in your payment but not in the duty amount
• Amended entries where a post-summary correction changed the duty amount after initial filing
• Partial payments where you paid duties in installments

If your numbers don’t match CBP’s, work with your broker to reconcile before filing. A $50 discrepancy on a single line can trigger manual review for your entire entry.

HTS code verification

Pull every line with an HTS code under 9903.01 or 9903.02. Then verify that:

• The code was correctly applied at the time of entry (not a misclassification)
• The goods actually fall under IEEPA tariff provisions
• The tariff ordinal number matches the specific IEEPA executive order provision

If you find entries where Section 301 duties (9903.88) or Section 232 duties (9903.80) were incorrectly coded as IEEPA, don’t include them in your CAPE claim. Those aren’t refundable under the Supreme Court ruling and including them will slow processing of your legitimate claims.

Liquidation status check

For each entry, determine whether it’s:

• Unliquidated — eligible for Post-Summary Correction (fastest path)
• Liquidated within 180 days — eligible for formal protest
• Liquidated beyond 180 days — may require CIT litigation

CAPE is designed to handle claims across all liquidation statuses, but knowing the status of each entry helps you prioritize. Entries approaching their 180-day protest window need protective filings now — don’t wait for CAPE.

Step 3: Resolve data quality issues

If your validation turns up problems, here’s how to fix them before the portal opens:

Missing entries in your ES-003. If you know you imported goods subject to IEEPA tariffs but the entries don’t appear in your report, the date range may be wrong, or the entries may have been filed under a different IOR number. Check with your broker.

Duty amounts that don’t reconcile. Work with your broker to pull the original entry summary from ACE and compare line by line. The broker can file amendments or corrections through ACE if needed.

HTS code misclassifications. If duties were assessed under the wrong HTS code at the time of entry, your broker can file a Post-Summary Correction (if the entry is unliquidated) to correct the classification before you file the CAPE claim.

Multiple brokers. If you used different brokers for different entries during the IEEPA period, you’ll need ES-003 data from each broker. CAPE processes claims at the importer level, not the broker level, so all entries under your IOR number are eligible regardless of which broker filed them.

Step 4: Prepare your filing package

Once your data is validated and clean, assemble your filing package:

1. Complete ES-003 export covering Feb 4, 2025 through Feb 24, 2026
2. Entry-level spreadsheet with each eligible line identified, including Entry Summary Number, HTS code, duty amount, and liquidation status
3. Duty calculation summary showing total claimed refund amount
4. ACH enrollment confirmation — verify your banking details are current with CBP
5. Power of Attorney — if filing through a representative, ensure the POA is active

An Impact Assessment produces all of this automatically. It validates your ES-003 data, identifies every eligible entry, calculates your estimated refund including statutory interest, flags data quality issues, and maps each entry’s liquidation status. When CAPE opens, you have a filing-ready package.

Step 5: What happens after you submit

Here’s the expected processing flow once you file through the CAPE portal:

Automated validation (minutes to hours)

CAPE receives your claim and runs automated checks: Does your IOR match? Do the entry numbers exist in ACE? Do the HTS codes fall under 9903.01 or 9903.02? Do the duty amounts match CBP’s records? Are you enrolled in ACH?

If everything checks out, your claim moves to automated processing.

Automated processing (days to weeks)

The Mass Processing Engine calculates your refund amount for each approved line, including statutory interest accrued from the date of overpayment. It batches approved claims for payment and generates a refund authorization.

Manual review (weeks to months — if triggered)

If the automated validation flags any discrepancies, your claim (or specific lines within it) routes to the Review and Liquidation Module for manual examination by a CBP officer. This is the bottleneck. With approximately 2,500 staff handling all manual reviews, claims in this queue could wait weeks to months depending on volume and complexity.

Common triggers for manual review:

• Duty amount mismatches greater than a de minimis threshold
• HTS codes that don’t match ACE records
• Entries with pending compliance actions or audits
• Entries with prior Post-Summary Corrections that may have already addressed the IEEPA duties
• Incomplete or missing data fields

Refund disbursement (days after approval)

Once approved, the Refund Disbursement module sends a payment instruction to Treasury. Funds are deposited via ACH. CBP hasn’t specified the exact disbursement timeline, but ACH transfers typically settle within 1-3 business days after the instruction is issued.

Validation rules: what will get flagged

Based on how CBP processes entries in ACE and the design constraints described in court filings, here are the likely validation rules CAPE will enforce:

Date range. Only entries with entry dates between February 4, 2025, and February 24, 2026, are eligible. Entries outside this window will be rejected automatically.

HTS code eligibility. Only HTS codes under headings 9903.01 and 9903.02 qualify. Any other Chapter 99 codes — including Section 301 (9903.88), Section 232 (9903.80), or other trade remedy provisions — will be rejected.

Duty amount accuracy. The claimed duty amount must match CBP’s records within a reasonable tolerance. Significant discrepancies trigger manual review.

Entry status. Entries must not have been previously refunded through another mechanism (e.g., a Post-Summary Correction that already removed IEEPA duties).

Importer identity. The filer must be the importer of record or an authorized representative with a valid POA on file.

If you can’t wait for CAPE

The CAPE timeline — portal launch in mid-April 2026 at the earliest, then 18-36 months for full processing — doesn’t work for every importer. If your IEEPA exposure is large enough that waiting years for a government refund creates a real cash flow problem, claim assignment through institutional buyers provides an alternative. You receive immediate, non-recourse capital based on your validated claim data, typically within 14-21 business days.

The government filing vs. immediate capital comparison breaks down the tradeoffs. Many importers use both: file clean, straightforward claims through CAPE for full recovery, and assign complex or high-value claims for immediate payment.

Filing through a representative vs. filing yourself

You have two options for CAPE filing: file directly through the portal yourself, or have your customs broker or another authorized representative file on your behalf. Each has tradeoffs.

Filing yourself

If you have direct ACE portal access and are comfortable navigating CBP systems, you can file your own CAPE declarations. This gives you full control over timing (you can file the moment the portal opens), data accuracy (you verify everything personally), and prioritization (you choose which entries to file first).

The downside: it requires ACE portal familiarity, time to enter data accurately, and comfort with CBP’s system interface. If you make errors in your filing, those errors are yours to fix.

Filing through your broker

Most importers will file through their customs broker, who already has ACE credentials and files entries daily. Your broker can file CAPE declarations under your IOR number using their existing Power of Attorney.

The advantage is expertise and efficiency — your broker knows the ACE system, understands CBP data formats, and can file accurately. The disadvantage is timing: your broker has many clients, and they may not prioritize your filing on day one. If queue position matters to you (and it should), have an explicit conversation with your broker about filing priority and timing.

The hybrid approach

Some importers are preparing both options: setting up direct ACE access as a backup while coordinating primary filing through their broker. That way, if the broker is delayed on launch day, the importer can file independently. This is particularly smart for importers with large IEEPA exposure where early queue position translates to significant time-value savings.

Tracking your claim after submission

Once you’ve filed through CAPE, you’ll want to track the status of your claim. While CBP hasn’t published detailed guidance on CAPE’s status tracking features, based on ACE’s existing functionality you can expect:

• Submission confirmation — a receipt or confirmation number when your claim is accepted by the portal
• Status indicators — likely showing whether your claim is in automated processing, manual review, approved, or disbursed
• Error notifications — alerts if your claim is rejected or requires additional information

Keep a log of every claim you submit: entry summary numbers, submission date, confirmation numbers, and current status. This log becomes essential if you need to follow up with CBP, escalate through the CIT, or coordinate with your broker on resubmissions.

If a claim is rejected, review the rejection reason carefully. Common reasons will likely include data mismatches, ineligible HTS codes, or missing information. Fix the issue and resubmit promptly — rejected claims that are resubmitted go back into the queue at the resubmission date, not the original filing date.

The preparation advantage

Every day you spend preparing before CAPE opens is time you save after it opens. Importers who show up on day one with validated, complete data packages will move through automated processing in days or weeks. Importers who scramble to pull data after the portal opens — or worse, file with errors that trigger manual review — will wait months or years.

The window for preparation is now. CAPE’s portal is weeks away. Your ES-003 data needs to be pulled, validated, reconciled, and organized. Your ACH enrollment needs to be confirmed. Your liquidation statuses need to be mapped. Your protest deadlines need to be tracked.