Frequently Asked Questions

In February 2026, the US Supreme Court ruled in Learning Resources, Inc. v. Trump that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. CBP is required to refund duties collected under IEEPA authority from February 2025 through early February 2026. The CAPE program, which launched April 20, 2026, is the mechanism for processing these refunds.

The ES-003 – officially the Entry Summary Line Tariff Details report – is a standard ACE Portal report that shows every line of your customs entries: HTS codes, duty amounts, entry dates, and liquidation status. It is the primary data source for identifying IEEPA-eligible duties and preparing your CAPE Declaration. Use ES-003, not TR-011. The TR-011 report was deactivated for IEEPA HTS codes on February 24, 2026 and no longer returns reliable data.

See the step-by-step ES-003 guide for export instructions.

CAPE stands for Consolidated Administration and Processing of Entries. It is the refund tool CBP built into ACE Portal, launched April 20, 2026. Instead of protesting entries individually, you upload a single CSV file containing your eligible entry numbers and CBP processes the refunds in bulk. Phase 1 covers unliquidated entries and entries liquidated within the past 80 days.

See the CAPE filing guide for step-by-step instructions.

Liquidation is CBP's official process of finalizing a customs entry and making the duty amounts permanent. When goods enter the US, the initial duty assessment is preliminary. Liquidation is when CBP closes the entry and locks the final numbers. After liquidation, those amounts are legally final unless challenged within 180 days via a Form 19 protest. A standard formal entry typically liquidates approximately 314 days after the entry date.

Full explanation: What Is Liquidation in Customs?

An unliquidated entry is a customs entry CBP has not yet finalized. The preliminary duties have been collected, but the entry is still open. Most formal entries are unliquidated for approximately 314 days after the entry date. If your ES-003 shows Unliquidated in the Liquidation Status field, the entry is eligible for CAPE Phase 1 immediately – no additional steps needed.

You likely qualify if all four conditions are met: you are the Importer of Record on the entries; your entry dates fall between February 4, 2025 and early February 2026; your entries contain IEEPA HTS codes (9903.01.xx or 9903.02.xx) with duty amounts greater than zero; and your entries are either unliquidated or liquidated within the past 80 days. If your entries are 80–180 days past liquidation, a Form 19 protest is the alternative path. Entries liquidated more than 180 days ago have no remaining option.

Full eligibility checklist.

IEEPA tariffs used HTS codes 9903.01.xx and 9903.02.xx – these are refundable through CAPE. Section 301 tariffs on Chinese goods use codes 9903.88.xx – these are not covered by CAPE and are not refundable. Section 301 was imposed under different legal authority and was not part of the court ruling that triggered the IEEPA refund. Section 232 (9903.80/81.xx) and Section 122 (9903.03.xx) are also not refundable through CAPE.

Full breakdown with HTS code table.

CAPE removes only the IEEPA lines (9903.01.xx or 9903.02.xx) and issues a refund for those duties. The Section 301 lines (9903.88.xx) are untouched – those duties are not refunded. For example, if your entry had $256 in Section 301 duties and $1,487 in IEEPA duties, CAPE refunds the $1,487 and the $256 stays paid. This is the intended behavior, not an error.

Liquidation Status and Liquidation Date are not included in the default ES-003 report configuration. You have to add them manually when setting up the report fields in ACE Portal. If your exported CSV file does not have those columns, regenerate the report with both fields explicitly selected. Without them, you cannot determine which entries qualify for CAPE Phase 1 versus which require a Form 19 protest.

Step-by-step: How to pull the ES-003 report with all fields.

Use ES-003. CBP deactivated IEEPA-related HTS codes in the TR-011 report on February 24, 2026 – the same day IEEPA tariffs ended. Running TR-011 today will return incomplete or missing data for 9903.01.xx and 9903.02.xx codes. ES-003 is the report CBP references in all official CAPE guidance and is the format CAPE preparation tools expect.

Yes. CAPE performs secondary validation on every uploaded Declaration and automatically removes entries that do not qualify for Phase 1. Ineligible entries are rejected with a reason code; the rest proceed normally. You do not have to pre-filter, though reviewing your ES-003 beforehand helps you understand what to expect and catch obvious issues like entries older than 80 days.

No. Once submitted, a CAPE Declaration cannot be modified or amended. If you discover entries you missed, create a second Declaration for those entry numbers. There is no penalty for filing multiple Declarations.

The second Declaration will be rejected for that entry. CBP will not process the same entry number twice. The first-submitted Declaration takes precedence. Do not attempt to refile an entry that is already in a pending Declaration.

Yes. A licensed customs broker can include up to 9,999 entries across different importers of record in a single CAPE Declaration. Each entry is tied to the IOR who originally filed it. The broker must have been the party that filed the original entry summaries for the entries included.

The filer code embedded in the entry number belongs to whoever filed the original entry summary with CBP – typically your customs broker's filer code if a broker filed on your behalf, or your own code if you self-filed. Use the filer code from the original entry, not your current broker's code if you have changed brokers since the shipment.

Not directly. If FedEx Logistics Inc appears as the IOR on your CF-7501, the IEEPA refund legally belongs to FedEx. Your recovery path depends on how duties were billed: if they appeared as a separate line item on your FedEx invoice labeled as customs duties or tariffs, contact FedEx Logistics customer service and ask about their IEEPA duty refund passthrough policy. If duties were bundled into the freight charge with no separate line item, the situation is more complex.

Full guide: DDP shipments and courier as IOR.

Under DDP (Delivered Duty Paid) terms, the supplier or their freight forwarder typically filed the customs entry and is the Importer of Record. The IEEPA refund legally goes to whoever is listed as IOR on the CF-7501 – not to you as the buyer. Check the IOR field on your CF-7501 to confirm who is listed. If a third party is the IOR, you cannot file a CAPE Declaration for those entries. Your options are to negotiate a passthrough with your supplier or their forwarder.

How to check who is the Importer of Record.

ACE Portal has been deactivating accounts with recent inactivity since CAPE Phase 1 launched. Clear your browser cache completely before every login and log in at least every few days to prevent the inactivity lock. If you are already locked out, call ACE Support – hold times are currently 2+ hours. Error Code 42 specifically means your account has been locked by the system and requires a phone call to reset. Using a private or incognito browser window also helps with session issues.

Full ACE Portal setup and troubleshooting guide.

ACH enrollment is how you give CBP your bank account details so they can deposit your refund electronically. All IEEPA refunds are issued via ACH – there is no check option. If ACH enrollment is missing or incorrect when CBP processes your refund, the payment will be rejected. As of March 2026, only 8.1% of affected importers had completed ACH enrollment. Set it up in ACE Portal under your Importer sub-account in the ACH Refund Authorization tab before your CAPE Declaration is accepted.

Step-by-step ACH enrollment guide.

Form 4811 (Special Address Notification) designates a third party – typically your customs broker – as the recipient of your refund payment on the IOR's behalf. You only need it if you want your broker to receive the refund directly rather than having CBP pay you. If you want the refund in your own bank account, you do not need Form 4811 – just ensure your own ACH enrollment is active in ACE Portal.

The 180-day protest window runs from the liquidation date. For February 2025 entries, which typically liquidated around December 2025, the protest deadline is approximately June 2026. For April 2025 entries, which typically liquidated around February 2026, the deadline is approximately August 2026. These are the two most urgent deadlines as of April 2026. Use the Liquidation Date field in your ES-003 to calculate your exact 180-day window – do not rely on estimates.

Full deadlines table by entry month.

Phase 1 excludes reconciliation entries (Type 09), drawback entries (Type 47), entries subject to antidumping or countervailing duties where the Department of Commerce has issued liquidation instructions, entries liquidated more than 80 days ago, Type 08 USMCA Duty Deferral entries, and entries not filed in ACE or lacking liquidation status in ACE. Warehouse entries are included in Phase 1 but refunds on those are issued after normal liquidation, not on the standard 60–90 day timeline.

CBP has confirmed Phase 2 will exist but has declined to provide a timeline, scope, or filing process as of April 2026. It is widely expected to cover entries Phase 1 excluded – primarily entries liquidated more than 80 days ago and AD/CVD entries where the refund is currently frozen pending Department of Commerce instructions. These are trade professional extrapolations, not official CBP statements. Do not wait for Phase 2 if you have approaching Form 19 protest deadlines – file the protest now to preserve your rights.

What to do while waiting for Phase 2.

Two separate timelines run from the date CBP accepts your CAPE Declaration. Unliquidated entries will be scheduled to liquidate within 45 days of acceptance. The refund payment arrives in your bank account within 60–90 days of acceptance. These are different clocks: your entry liquidates around day 45, but the money arrives closer to day 60–90. For entries already liquidated within the 80-day window, CBP reliquidates the next business day; the 60–90 day payment timeline still applies.

CBP has not announced a closing date for CAPE Phase 1. You can file at any time while Phase 1 is open. The urgency is not about a CAPE filing deadline – it is about Form 19 protest deadlines for entries outside the 80-day window. Those are fixed statutory deadlines: approximately June 2026 for February 2025 entries and August 2026 for April 2025 entries. They cannot be extended.

Check your specific deadline.