CAPE Phase 1 Refunds: What NVOCCs Should Tell Their Importer Clients Now

CBP launched CAPE Phase 1 on April 20, 2026 (CSMS # 68396594). The process allows certain importers of record to request refunds of IEEPA duties through a CAPE Declaration filed in the ACE Portal — but eligibility criteria, process steps, and refund timing may change. Confirm current CBP guidance before relying on this content. Here's what NVOCCs and freight forwarders need to understand about the process.

This article discusses CAPE Phase 1 and IEEPA duty refund procedures based on CBP's official announcements (CSMS # 68315804, # 68340863, and # 68396594) and CBP's IEEPA Duty Refunds guidance, re-verified as of July 31, 2026. CAPE eligibility, deadlines, process steps, refund timing, and CBP review practices may change. Importers and brokers should confirm current CBP guidance before relying on this process.

CBP launched Phase 1 of the Consolidated Administration and Processing of Entries (CAPE) tool on April 20, 2026, announcing the activation in CSMS # 68396594. Under CAPE Phase 1, importers of record (IORs) and licensed customs brokers may file CAPE Declarations through the ACE Secure Data Portal for eligible entries where IEEPA duties were paid. The process is not automatic — it requires identifying eligible entries, confirming proper account setup, and working through a licensed customs broker.

For NVOCCs and freight forwarders, your importer clients are likely going to ask about this. Being prepared with accurate, practical information — and knowing when to involve the customs broker — is one of the most useful things you can do.

CAPE Phase 1 refunds are real — but they are not automatic and not simple. Each entry must be reviewed for eligibility, the importer must have ACE Portal access and ACH refund enrollment in place, and a licensed customs broker must prepare and submit the CAPE Declaration. Moving without confirming all of these creates delays or blocks the refund entirely.

Have importer clients asking about CAPE refunds? A short process review can help identify potentially qualifying entries, confirm current eligibility criteria, and coordinate what needs to be in place before filing.

What Is CAPE Phase 1?

CAPE stands for Consolidated Administration and Processing of Entries — CBP's tool for consolidating refunds of IEEPA (International Emergency Economic Powers Act) duties, including interest, rather than processing refunds entry by entry. Per CBP's launch announcement (CSMS # 68396594), CAPE Phase 1 is limited to certain unliquidated entries and certain entries within 80 days of liquidation. Importers of record who paid IEEPA duties on qualifying entries may be eligible to request refunds. The refund process, as CBP describes it, involves:

• Identifying entries where IEEPA duties may have been collected, subject to Phase 1 eligibility criteria
• Submitting the CAPE Declaration as a CSV file through the ACE Secure Data Portal — not through ABI — with the IOR and licensed customs broker each holding ACE Portal accounts and ACH refund enrollment completed in ACE
• CBP review and validation — after a declaration is processed and validated, ACE liquidates or reliquidates the entries by removing the IEEPA Chapter 99 HTS provisions and corresponding duties, subject to CBP compliance review
• Refund issued to the IOR's bank account recorded in ACE, or to a party the IOR has designated via CBP Form 4811

This should be reviewed carefully before filing. Not all entries will qualify, eligibility criteria apply, and submitting incomplete or inaccurate declarations can delay or block refunds. Working with a licensed customs broker before filing is strongly recommended.

Why NVOCCs and Forwarders Should Pay Attention

The importer of record receives any refund — not the NVOCC or forwarder. But as the operational partner closest to many importer clients, you may be the first point of contact when they hear about CAPE and start asking questions.

NVOCCs and forwarders can add real value without overstepping. The right role is to help clients understand what the process involves, gather the shipment and entry information they'll need, and connect them with the right customs broker to handle the filing side. Do not guess on eligibility or promise refunds — the facts of each entry matter.

Step-by-Step: How the CAPE Refund Process Works

1. Identify entries where IEEPA duties may have been paid — pull entry records for the relevant period.
2. Compile the entry numbers and related shipment documentation.
3. Review whether the entries may qualify under the CAPE Phase 1 criteria.
4. Confirm the importer has active ACE Portal account access and has completed ACH refund enrollment in ACE.
5. Coordinate with the customs broker to prepare and submit the CAPE Declaration.
6. Monitor the CBP review process and refund status through ACE.

Every step matters. Missing documentation, an unconfigured ACH account, or an ineligible entry can stall the entire process. Starting with a complete picture of the shipment records is essential.

Common Mistakes That Can Delay or Block Refunds

Most CAPE refund problems are preventable. The issues we see most often are:

• Missing entry numbers — all entries must be listed accurately in the CAPE Declaration
• No ACH refund enrollment in ACE — CBP cannot issue the refund without it
• Multiple customs brokers involved without coordination — creates gaps in who files what
• Assuming refunds are automatic — they are not; each entry must be reviewed and filed
• Submitting before eligibility is confirmed — can result in a rejected or delayed declaration
• Including late or ineligible entries — strict deadlines and eligibility criteria apply

Who Does What?

Understanding each party's role prevents confusion and ensures nothing falls through the cracks.

Importer

Owns eligibility, controls the ACE Portal account and ACH refund enrollment, and receives the refund. Per CBP guidance, refunds are issued to the IOR's bank account recorded in ACE or to a party the IOR has designated via CBP Form 4811. The importer must authorize and engage in the process — neither the broker nor the forwarder can act without their involvement.

Customs Broker

Reviews entry data, confirms eligibility, prepares the CAPE Declaration, and submits it through ACE. Per CBP guidance, the CAPE Declaration is submitted as a CSV file through the ACE Secure Data Portal — not through ABI — and both the IOR and the licensed customs broker must have ACE Portal accounts. A licensed customs broker is the right party to handle the actual filing — this is not a process importers should attempt without one.

NVOCC / Forwarder

Guides the importer client through what the process involves, helps organize shipment and entry records, and connects the client with the customs broker. Acts as the operational coordinator — not the filer.

CBP

Reviews the CAPE Declaration submission and validates the entries and eligibility. Per CBP guidance, after processing and validation, ACE liquidates or reliquidates the entries by removing the IEEPA Chapter 99 HTS provisions and corresponding duties. Refunds are issued via ACH where applicable — unless a compliance concern requires further CBP review. CBP has not published a definition of what constitutes a compliance concern or triggers further review.

CAPE Refund Readiness Checklist

Before initiating the CAPE Declaration process, confirm the following are in place:

• Entry numbers list compiled for all relevant shipments
• IEEPA duties confirmed as paid on those entries
• ACE Portal account access confirmed and active for the importer
• ACH refund enrollment completed in ACE — required for CBP to issue the refund
• Eligibility reviewed — not all entries with IEEPA duties will qualify
• Licensed customs broker aligned and ready to prepare and file the declaration

Incomplete setup can delay or block refunds. Going through this checklist before engaging the broker saves time for everyone involved.

Ready to Review CAPE Eligibility for Your Importer Clients?

Suggested Message NVOCCs Can Send to Importer Clients

If you want to proactively inform your importer clients about CAPE Phase 1, here is a short, accurate message you can use or adapt:

CBP launched CAPE Phase 1 on April 20, 2026 (CBP CSMS # 68396594). The process allows certain importers to request refunds of IEEPA duties through the ACE Portal, but refunds are not automatic — eligibility, ACE Portal account setup, ACH refund enrollment, and customs broker coordination are all required. If you believe your company paid IEEPA duties on qualifying entries, we can help connect you with AP Customs to review next steps. Please confirm current CBP guidance before taking action.

Refund Timing

Per CBP's IEEPA Duty Refunds guidance, importers and authorized brokers should anticipate that valid IEEPA refunds will generally be issued within 60 to 90 days following acceptance of the CAPE Declaration, unless a compliance concern requires further CBP review. CBP has not published a definition of what constitutes a compliance concern or triggers further review. Refund timing is not guaranteed and may vary depending on the specific entries and CBP processing.

Primary claims in this article are drawn from CBP's official CAPE announcements (CSMS # 68315804, # 68340863, # 68396594) and CBP's IEEPA Duty Refunds page, re-verified July 31, 2026. Diaz Trade Law's IEEPA refund commentary is cited as secondary analysis only. Importers and brokers should confirm current CBP guidance and ACE functionality before taking action.

This article is for general informational purposes only and is not legal advice. Eligibility and filing requirements should be reviewed based on the specific facts of each entry.