Small importers finally have a path to recover some IEEPA tariff duties, but the path is not "wait for a check."
U.S. Customs and Border Protection says it has launched CAPE, the Consolidated Administration and Processing of Entries function inside the ACE Secure Data Portal, to process valid refund requests for duties imposed under the International Emergency Economic Powers Act. The agency says CAPE is meant to consolidate IEEPA duty refunds, including interest, instead of handling them one entry at a time. CBP
That sounds like administrative plumbing. For a small retailer, ecommerce seller, wholesaler, repair business, or manufacturer that imports parts, it can be cash.
But the owner takeaway is blunt: the refund process rewards clean records, current portal access, and the right filing party. If you assume the money will find you, it probably will not.
The Filing Party Matters
CBP says CAPE Declarations can be filed only by the importer of record or by the licensed customs broker that filed the entries on behalf of that importer. Attorneys cannot file the declaration for an importer. A broker can file entries for multiple importers, but the importer and broker still have to be properly tied to the entries in ACE.
That is the first trap for small businesses.
Many owners think they "imported" a product because they paid the supplier invoice, absorbed the tariff cost, and sold the inventory. Customs paperwork may say something more specific. The importer of record might be the business, a supplier, a freight forwarder, or another party in the chain.
Before spending hours on refund math, pull the entry documents and answer one question: who is listed as the importer of record?
If it is you, make sure your ACE Portal access works. If it is your broker, ask them what they have already filed and how they will report claim status back to you. If it is a supplier or freight forwarder, you may need a commercial conversation about whether they can claim the refund and whether any credit flows back to you.
That conversation is awkward. It is still better than discovering later that the refund path never ran through your company.
The Window Is Not Unlimited
CBP says Phase 1 covers certain unliquidated entries and certain entries within 80 days of liquidation. Phase 2 adds entries flagged for reconciliation where the reconciliation entry is not yet on file. The agency says it is evaluating more complicated scenarios for later phases.
In practice, that means timing and liquidation status matter.
If your business imports regularly, do not treat the refund question as a year-end accounting cleanup. Build a list of potentially affected entries now. Include entry number, entry date, liquidation status, broker, importer of record, IEEPA duty amount, and whether the entry is tied to reconciliation.
CBP also says a CAPE Declaration is filed through ACE using a CSV file and that each declaration can include up to 9,999 entries. Once accepted, it cannot be amended. If you later find additional eligible entries, CBP says you need to file a new declaration.
The practical lesson: do not rush a sloppy upload, but do not let the perfect spreadsheet become the reason you miss the easier window.
ACH Details Can Stop the Refund
The second trap is payment setup.
CBP says refunds require bank account information in the ACE Portal and that refunds are paid electronically through ACH. If refund ACH information is not current, the refund will not be paid until the information is provided.
This is where small businesses lose time. The person who knows imports may not control banking. The person who controls banking may never log into ACE. The broker may file the CAPE Declaration, but the importer may still need visibility into refund status and payment details.
Assign one owner inside the company for the whole chain:
- ACE Portal access
- ACH refund enrollment
- broker coordination
- entry list cleanup
- accounting treatment when money arrives
Do not split those responsibilities across four inboxes and hope everyone assumes someone else handled it.
Do Not Wait for an Email
CBP is also warning importers about scams tied to the refund process. The agency says fraudsters are using emails, notices, social media, and other methods to solicit secure company and personal information from importers.
The simplest rule is also the safest: CBP says it will not email CAPE refund status updates, reports, or related documents. Importers should use ACE Reports, or request information from the customs broker if the broker filed the declaration.
CBP says ACE users with importer sub-account access can monitor refund activity through reports including ES-022 for CAPE entry summaries, REV-603 for trade refunds, REV-613 for rejected ACH refunds, and REV-615 for CAPE-specific refund details once refunds are issued.
For owners, that means a "CBP refund update" email asking for banking details should be treated as hostile until proven otherwise. Do not click it. Log into ACE directly or call the broker using a phone number you already trust.
The Refund May Not Match Your Spreadsheet
CBP says valid IEEPA refunds are generally issued within 60 to 90 days after acceptance of the CAPE Declaration unless compliance concerns require more review. It also notes that some refunds are issued at liquidation for entries with certain statuses.
The amount may not be exactly what the business expects. CBP says refunds can be netted against other duties, taxes, fees, and legally fixed unpaid debts. The agency also says some original entry filings may have calculated duties incorrectly, which can change the final amount after CAPE processing.
That matters for cash planning.
Do not spend the refund before it arrives. Do not book the full amount as guaranteed cash. Treat it as a receivable only after your accountant or broker is comfortable with the status, amount, and timing.
The Useful Move
If you import goods, make this a 30-minute task this week.
Ask your broker for a list of entries with IEEPA duties. Confirm who is the importer of record. Check whether your ACE Portal account is active. Confirm ACH refund enrollment. Ask whether any CAPE Declarations have already been filed. Then decide who will monitor ACE reports until the money is issued, rejected, offset, or clearly ineligible.
The refund process is not impossible. It is just paperwork-sensitive.
For a large importer, that is annoying. For a small business, it can be the difference between recovering cash and watching it get stuck behind a forgotten login, a stale bank record, or a broker conversation nobody started.