When FedEx or UPS Keeps Your IEEPA Refund: Notify Party, Box 28, and What to Do

TL;DR — CBP routes IEEPA refunds to the IOR by default. A refund goes to a different party — a Form 4811 notify party — only when both conditions are met: (1) the notify party is on file in the importer's ACE profile, and (2) the notify party's IR# is listed in box 28 "Reference Number" of the CBP Form 7501. If only one condition exists, the refund still goes to the IOR. When FedEx, UPS, or DHL handled your entries as customs broker, they may meet both conditions — and the refund flows to them first. The 4811 designation directs payment but does not transfer ownership; recovery from a broker that already received the refund is a private contractual matter, not a CBP one. If your refund never arrived in your bank, the configuration in your ACE profile and box 28 of your entries is where to look first.

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How CBP routes IEEPA refunds — and the two conditions that actually matter

CBP consolidates IEEPA refunds by recipient and liquidation date. Per CBP's IEEPA Duty Refunds guidance, eligible recipients are the Importer of Record (IOR) or the party the IOR has designated on CBP Form 4811 to receive refunds on its behalf.

CBP is only able to refund IEEPA duties to the Importer of Record or the Notify Party (designated on CBP Form 4811) who have their U.S. bank account information in their ACE Portal account.

— CBP IEEPA Duty Refunds page

The mechanic gets more specific in CSMS #67648307 (February 6, 2026), which states that refunds are directed to a notify party only if two conditions are met: (1) the notify party is on file in the importer's ACE profile, and (2) the notify party's importer of record (IR) number is listed in box 28 "Reference Number" of the CBP Form 7501 (or its electronic equivalent).

This two-condition rule is the most important operational fact in the entire refund routing question. The conditions are conjunctive — both must hold. If a broker is on file as a notify party in your ACE profile but is not referenced in box 28 of a given entry's CF-7501, the refund for that entry still goes to the IOR.

Importers reporting refunds that never came through often discover one of these conditions met without their direct knowledge — typically from a paper Form 4811 filed years earlier, or from a brokerage agreement that authorized box 28 routing as a default. Importers may have multiple notify parties on file in their ACE profile simultaneously. Which one (if any) receives a refund for a specific entry is determined per-entry by what appears in box 28.

In practice, this happens often. High-volume brokers — FedEx, UPS, DHL on parcel imports, plus traditional licensed brokers on business shipments — are sometimes designated as 4811 notify party with refund routing. The designation appears in both the ACE profile and box 28 across affected entries.

Which entries CAPE Phase 1 actually covers

Routing matters most for entries that qualify for CAPE Phase 1 — currently the exclusive refund mechanism for IEEPA duties. Per multiple legal advisories tracking the rollout, Phase 1 covers two categories:

1. Unliquidated entries — most entries from the last 10 to 12 months that CBP has not yet finalized.
2. Entries within 80 days of liquidation — a rolling window.

Entries that liquidated more than 80 days ago fall outside Phase 1. For those, recovery requires either a protest under 19 U.S.C. § 1514 (within the 180-day post-liquidation window) or a CIT action to preserve refund rights. CBP has not yet announced the scope of Phase 2.

The Form 4811 process today

CBP CSMS #67648307 (effective February 6, 2026) modernized the Form 4811 process. Previous versions of the paper form are deprecated. The updated version 12/25 remains acceptable, alongside a new self-service Notify Parties tab in ACE Portal.

Under current rules, importers can add or modify a notify party in either of two ways:

1. Email the updated CBP Form 4811 (version 12/25) to the assigned Center of Excellence and Expertise (CEE), or
2. Use the "Add Notify Party" feature in the Notify Parties tab in the Importer sub-account view of ACE Portal.

To revoke a notify party, only the email-to-CEE option exists. There is no self-service revocation in ACE Portal.

What changed in 2026 is the timing of refund issuance. CAPE Phase 1 launched April 20, 2026 at 8:00 AM EDT. The first ACH refunds began transmitting May 12, 2026. Routing decisions that were theoretical for years are now real money landing in real accounts — and the wrong account, if both conditions favor a broker the IOR forgot was designated.

FedEx itself acknowledges the dynamic in its tariffs FAQ, directing readers that Importers of Record listed as notify party should confirm an ACE Portal Refund account and ACH setup. The carrier identifies the same configuration this guide addresses — and points the IOR to verify it.

For a deeper walkthrough of the CAPE Declaration mechanics, see our step-by-step ES-003 retrieval guide.

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Three things to check in ACE before your refund moves

Three artifacts in ACE, taken together, confirm whether either of the two routing conditions actually applies to your entries: your Notify Parties tab (condition 1), your CF-7501 box 28 per-entry (condition 2), and your CAPE refund tracking reports (where the routing decision shows up after the fact).

Pull your Notify Party assignments (condition 1)

Navigate to the Notify Parties tab in your ACE Portal Importer sub-account:

Accounts → Importer sub-account → Notify Parties tab

The tab lists the parties currently designated on your account by notification type — refunds, bills, or liquidation notices. Multiple notify parties can be on file simultaneously, each with different notification scopes. Only a Trade Account Owner (TAO) can add or edit notify parties self-service. Removing requires emailing your CEE (see Section 4).

If you don't see the Notify Parties tab at all, verify you are signed in to the Importer sub-account, not the Top Account. As we documented in our REV-603/613/615 reports guide, running reports from the Top Account returns no data even when filings exist — this is the most common reason all three look empty when they're not.

A broker on file in your Notify Parties tab is necessary but not sufficient for refund diversion. If you see one but no entries show that broker's IR# in box 28, your refunds still route to you as IOR.

Check box 28 on your CF-7501s per entry (condition 2)

Pull your CF-7501 entry summaries for the relevant entries. Box 28 is labeled "Reference Number." The IR# of any 4811 notify party designated to receive a refund for that entry appears there.

If box 28 contains your own IR# or is blank, the refund routes to you. If box 28 contains a different IR# matching a notify party on file in your ACE profile, the refund routes to that party.

For bulk verification across many entries, the ACE Reports system lets you add Notify Party data elements to an Entry Summary report. This shows the box 28 reference per entry without pulling each 7501 individually. For exact field names and configuration, see CBP's ACE Reports Trade Refund Report Quick Reference Card linked from the IEEPA Duty Refunds page.

A broker may be in your ACE profile and listed in box 28 on some entries but not others. The IOR is responsible for confirming the per-entry state — CBP will not flag a mismatch.

Run your CAPE refund tracking reports

After the routing decision happens, three ACE reports together cover the refund lifecycle:

ES-022 — CAPE Entry Summary Report. Links each CAPE Declaration to its constituent entries and refund numbers. Refund amount and interest amount appear as separate columns. ES-022 is the first report to populate after a CAPE submission.

REV-603 — Trade Refund Report. Shows the Refund Secondary Status for each refund: Sent to Treasury, Treasury Issued, Funds Diverted, or Check/ACH Returned. The Funds Diverted status indicates CBP applied an offset under 19 CFR §§ 159.1 and 24.72 before disbursement — an outstanding customs debt netted against your refund.

REV-615 — Trade CAPE Detail Refund Report. Per CBP, this report provides consolidated CAPE refund information as well as entry-level refund detail. It is the only report that ties directly to a CAPE claim number. If your CAPE tab shows accepted but REV-603 is blank, REV-615 is where to look first.

All three live at:

Reports → Folders → Public Folders → ACE → Trade → Importer or Broker → Revenue → Refunds

For full breakdowns of each report and when each populates, see the REV-603/613/615 walkthrough. If your bank deposit doesn't match the expected total, our reconciliation guide for ES-022 vs. ACH deposits covers the most common gaps.

The ACH trace number in REV-615 is the critical field for a refund that left CBP but never landed in your account. If a trace number is present and the funds didn't reach your bank, the refund went somewhere — and the routing path traces back to whether both conditions were met for a notify party.

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What FedEx, UPS, and DHL have pledged — and where the pledges stop

Following the Supreme Court's February 20, 2026 ruling in Learning Resources, Inc. v. Trump, the three major international parcel carriers issued public statements about IEEPA refunds. Read carefully, the three statements differ in scope.

FedEx made the broadest pledge. The carrier committed to issue refunds to shippers and consumers who originally bore the charges — without scope-limiting the commitment to entries where FedEx was the IOR. The pledge appears in identical form across FedEx's tariffs page, official press statements, and customer communications. FedEx also separately filed its own CIT action seeking a full refund of IEEPA duties it paid.

UPS pledged within a scope-limited frame. UPS's published statement applies specifically to shipments where UPS itself was the Importer of Record. For those entries, UPS commits to file refund claims, retrieve the funds from CBP, and pass them through to the original payors. The pledge does not extend to entries where the customer was the IOR and UPS served as broker only.

DHL's pledge is the most explicit on scope. DHL Express publicly distinguishes two scenarios. For shipments where DHL Express acted as IOR, DHL will file refund claims automatically and pass the proceeds to the original duty-payor. For shipments where the customer served as IOR and DHL provided customs brokerage services only, DHL states refund claims must be initiated by the customer directly through CBP's processes or through an authorized representative.

The DHL scope-distinction is what this guide exists for. The carrier industry itself acknowledges that when the customer is the IOR, the refund mechanic is the customer's responsibility — and by extension, the routing configuration in the customer's ACE Portal is what determines where the refund lands.

For the legal posture of these pledges generally, the controlling principle comes from a Holland & Knight advisory on CAPE:

Though CBP Form 4811 (filed at the time of entry) may direct where a refund is sent, it does not transfer ownership.

— Holland & Knight, "CAPE Has Arrived" (April 2026)

That distinction is the operational hinge of this entire guide. CBP discharges its obligation when it pays the designated party. The IOR's recovery from a broker that received the refund is a private contractual matter.

Public pledges are statements of intent — useful in a written demand, but not contracts.

This is the legal reality being tested in the active class actions. The Reiser v. FedEx complaint argues that public pledges of this kind are not legally binding consumer guarantees absent specific contractual commitment.

For the IOR with material IEEPA tariff exposure as of mid-2026, three things follow.

First, the broker's pledge — if any — is meaningful evidence of intent, useful in a written demand.

Second, the pledge does not substitute for verifying the two routing conditions in ACE before refunds move. Once the refund leaves CBP, leverage shifts from administrative (revoking a designation) to commercial (negotiating with the broker for pass-through).

Third, the cleanest path is to remove the broker as 4811 notify party for refund purposes before any further refunds issue — even when the broker has pledged pass-through.

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How to revoke a 4811 notify party designation

Adding a notify party in ACE Portal is self-service. Removing one is not.

Adding a notify party is self-service. Removing requires an email to your CEE — by design.

Per CBP CSMS #67648307, revocation of notify party information is accomplished only by email to the appropriate Center of Excellence and Expertise (CEE). The Notify Parties tab in ACE Portal does not have a self-service removal function. The asymmetry is deliberate — CBP wants additions to be fast and removals to be reviewed.

Step 1 — Determine your assigned CEE. CEE assignment is based on the HTSUS classification of the predominant number of goods you import. Your assigned CEE appears in your ACE Portal account view. If no CEE is currently assigned, CBP guidance directs contacting the Center that most closely aligns with the tariff number of the importer's highest-valued commodity.

Step 2 — Email the CEE. No phone calls. Send a written email so you have a paper trail. The email should include:

• Your importer name and IR# (Importer of Record number)
• Specific entry numbers, or a date range covering the affected entries
• The party currently designated as notify party — with their EIN or filer code
• The action requested: revoke the 4811 notify party designation for refund purposes
• A request for confirmation when the revocation is processed

Reference CSMS #67648307 in case the CEE specialist needs context for the request.

Step 3 — Wait for confirmation. CBP does not publish a target turnaround, and Center workload varies. Document the email sent and the date in case the broker refiles a designation in the meantime. Also confirm in writing what entries the revocation covers — going forward, or also affecting pending CAPE Declarations.

The 10 Centers and their email contacts

Center	Email	Phone
Agriculture & Prepared Products	cee-agriculture@cbp.dhs.gov	(866) 295-7624
Apparel, Footwear & Textiles	cee-apparel@cbp.dhs.gov	(866) 295-7624, code 04
Automotive & Aerospace	cee-automotive@cbp.dhs.gov / cee-aerospace@cbp.dhs.gov	(734) 608-5570
Base Metals	cee-basemetals@cbp.dhs.gov	(312) 542-5758
Consumer Products & Mass Merchandising	cee-consumer@cbp.dhs.gov	(866) 295-7624, code 08
Electronics	cee-electronics@cbp.dhs.gov	(866) 295-7624, code 07
Industrial & Manufacturing Materials	cee-industrialmaterials@cbp.dhs.gov	—
Machinery	cee-machinery@cbp.dhs.gov	—
Petroleum, Natural Gas & Minerals	cee-petroleum@cbp.dhs.gov	—
Pharmaceuticals, Health & Chemicals	cee-pharmaceuticals@cbp.dhs.gov / cee-chemicals@cbp.dhs.gov	—

For appeals of CEE assignment itself: CEE@cbp.dhs.gov.

The legal basis for the Centers structure is 19 CFR § 101.10. The directory is maintained at cbp.gov/trade/centers-excellence-and-expertise-information/cee-directory.

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If your refund already went to the broker

The harder scenario is the refund that already issued elsewhere. You check your bank, the refund never arrived, and the ACH trace number in REV-615 leads to an account that isn't yours.

Both conditions were met without your direct awareness, CBP discharged its obligation, and recovery is now between you and the broker. Three operational paths follow, in increasing escalation.

Path 1: formal demand referencing the carrier's pledge

If your broker is giving you the run-around — vague responses, claims they have "no authority" over the refund, deflection to CBP's process — your strongest leverage is the carrier's own public pledge.

Read the pledge carefully to confirm it covers your specific scenario. FedEx's broad pledge applies regardless of IOR identity. UPS and DHL pledges apply specifically when the carrier was the IOR; for customer-as-IOR entries, the carrier's published commitment may not extend to a pass-through obligation.

A written demand letter referencing the applicable pledge, identifying the specific entries, and providing documentation of duty payment can produce a settlement without further escalation — especially for established business relationships.

Documentation to include:

• CF-7501 entry summaries showing the IOR's identity and the box 28 reference
• ACH refund enrollment confirmation from your ACE Portal
• REV-603 or REV-615 reports showing the refund was issued
• ES-022 showing refund amount and interest
• Original duty payment records (importer invoice, bank statement)
• Copy of the carrier's published pledge with date retrieved

A reasonable demand timeline is 30 to 60 days for written response. If the broker confirms receipt and commits to a pass-through schedule, document the commitment in writing and follow up on the cadence.

Path 2: joining an existing class action

As of March 2026, per an Arnold & Porter advisory, multiple consumer class actions have been filed against carriers and downstream retailers. Active cases include:

• Reiser v. Fed. Express Corp. (S.D. Fla. No. 1:26-cv-21328) — filed by Morgan & Morgan, arguing FedEx's pledge is not legally binding
• Ward v. EssilorLuxottica S.A. (E.D.N.Y. No. 1:26-cv-01133)
• Anastopoulo v. FedEx Corp. and Anastopoulo v. United Parcel Serv. Inc. — four cases filed by Hali Anastopoulo, a freight forwarder and customs broker based in South Carolina, in district courts in South Carolina, Georgia, and Tennessee
• Stockov v. Costco Wholesale Corp. (N.D. Ill. No. 1:26-cv-02734) — filed March 11, 2026, arguing a "double recovery" theory where a retailer keeps refunds without passing them to consumers
• A parallel state-court action against Fabletics filed March 6, 2026 in Cook County, Illinois, under the Illinois Consumer Fraud and Deceptive Practices Act

A critical scope distinction: most of these actions focus on de minimis parcel imports under Section 321 (suspended worldwide August 29, 2025 under Executive Order 14324) and consumer-level overcharges. Business IORs whose refund routing was diverted to a broker for full importer-level entries may or may not fit cleanly into one of the existing consumer classes. The legal theories overlap (breach of contract, unjust enrichment, deceptive trade practices) but the class definitions vary.

Tracking the active litigation through Arnold & Porter, Sullivan & Cromwell, or Covington & Burling tariff litigation advisories is more reliable than ad hoc news coverage.

Path 3: CIT litigation for past-deadline or larger exposures

For entries past the 180-day protest window under 19 U.S.C. § 1514, or for refund disputes exceeding the practical economics of a class action settlement, individual CIT litigation is the remaining path. Per Covington & Burling reporting in March 2026, more than 2,000 companies have filed direct refund cases in the Court of International Trade since the Supreme Court ruling — including Costco, Revlon, Bumble Bee Foods, Kawasaki Motors, Yokohama Tire, EssilorLuxottica, Goodyear, BorgWarner, GoPro, and various Toyota subsidiaries.

CIT litigation requires a licensed customs attorney. Hourly rates run $500 to $1,500. The cost threshold to make litigation rational is typically $50,000 or higher in disputed refunds.

None of the above is legal advice. Consult a licensed customs attorney for your specific entries, documentation, and exposure.

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Preventing this on new entries

For IORs still receiving IEEPA-bearing entries, or any entries that may eventually qualify for refunds, the preventive steps are short.

1. Confirm an ACE Portal Importer sub-account exists in your name. Apply at the Applying for an ACE Portal Importer Account page if not.

2. Enroll in ACH refunds — separately from ACH payment setup. This is the most commonly missed step. Per Troutman Pepper Locke analysis, ACH refund enrollment must be completed in ACE for a refund-specific bank account; having ACH set up only for duty payments is not sufficient. As of mid-2026, more than 12,300 refunds had already been rejected because recipients had no valid ACH refund information on file, and only a small fraction of importers had completed the enrollment.

3. Add yourself as 4811 notify party with refund designation (optional but cleanest). Your Trade Account Owner can do this in the Notify Parties tab. The cleanest configuration is the IOR itself — refunds route back to the same account that paid the duties. Designating yourself adds a layer of confirmation but is not required for refunds to route to you as IOR by default.

4. Confirm your 5106 contact information is current. Email and phone on file determine where CBP sends correspondence about pending refunds.

5. Decide who should be the notify party for refunds going forward. Options:

   • Yourself (default and cleanest)
   • An affiliated subsidiary with a separate IR#, for structural reasons
   • A trusted advisor with explicit power of attorney
   • Not your broker by default — this is where most diverted refunds originate

6. If a broker is currently listed as your 4811 notify party for refund purposes, and that broker's IR# appears in box 28 on your CF-7501s, revoke the designation through the appropriate CEE before any further refunds issue (see Section 4).

Notes before filing your CAPE Declaration

A few operational caveats apply once you are ready to file CAPE.

Post-Summary Corrections (PSCs) cannot be used to request IEEPA duty refunds. CAPE is the exclusive mechanism for those. PSCs can still be used to correct other underlying entry data — value, classification, country of origin. CBP recommends filing any necessary PSCs before submitting the CAPE Declaration, so that the recalculation runs against corrected entry data.

A CAPE Declaration cannot be amended once accepted. Any entry included on an accepted declaration cannot be resubmitted on another. Review entry numbers carefully before uploading. If a declaration is rejected during validation, the filer can correct and resubmit; once accepted, the structure is locked.

CAPE filing authority is restricted. Only the IOR or the licensed customs broker who originally filed the underlying entries can file a CAPE Declaration, and the filing broker must hold a valid Power of Attorney. Per CBP's official IEEPA Duty Refunds page, third-party trade consultants, freight forwarders without brokerage licensing, and authorized agents who were not the original filer cannot file CAPE — even with a current POA. As an IOR you can always file CAPE yourself. If you have changed brokers since the original entry filing, the new broker cannot file CAPE for those legacy entries on your behalf.

Drawback claims. Per Great Lakes Customs Law guidance, the CAPE Declaration must be submitted before any drawback claim on the same entries. Once drawback is claimed, the entry is excluded from CAPE Phase 1.

If you want to model your refund exposure entry-by-entry before submitting a CAPE Declaration, our Pre-CAPE Audit tool processes ES-003 reports locally in your browser without uploading data to any server.

Frequently Asked Questions

Does my customs broker automatically receive my IEEPA refund?

Only if two conditions are both met: (1) the broker is on file as a 4811 notify party in your ACE Portal Importer profile, and (2) the broker's IR# is listed in box 28 "Reference Number" on the CBP Form 7501 for the specific entry. If either condition is missing, the refund routes to you as IOR by default.

Which of my entries qualify for CAPE Phase 1?

Phase 1 covers unliquidated entries plus entries within 80 days of liquidation. Older liquidated entries require a protest under 19 U.S.C. § 1514 or a CIT action. See the Phase 1 scope explanation in Section 1 above for context.

Is FedEx's pledge to refund customers legally binding?

Public pledges are statements of intent. The Reiser v. FedEx complaint and other active class actions argue these pledges do not amount to legally binding consumer guarantees absent specific contractual language. The pledges are useful evidence in a written demand but are not enforceable in the way a contract clause would be.

Do UPS and DHL pledges cover the same scenarios as FedEx?

No. FedEx's published pledge is broad — it commits to refund shippers and consumers who originally bore charges, regardless of IOR identity. UPS's published pledge applies specifically to shipments where UPS was the IOR. DHL's pledge similarly applies only when DHL Express acted as IOR; DHL explicitly states that customer-as-IOR refund claims must be initiated by the customer directly.

How do I check who is currently listed as my notify party in ACE?

Navigate to Accounts → Importer sub-account → Notify Parties tab. For per-entry verification, pull your CF-7501 forms and check box 28 ("Reference Number"). For bulk verification across many entries, run an Entry Summary report in ACE Reports and add the Notify Party data fields.

Can I revoke a 4811 notify party designation in ACE Portal myself?

No. Adding a notify party is self-service for the Trade Account Owner. Revocation requires an email to your assigned Center of Excellence and Expertise. CBP does not provide self-service revocation in the ACE Portal interface.

Which Center of Excellence and Expertise handles my account?

Assignment is based on the HTSUS classification of your predominant imported goods. Your assigned Center appears in your ACE Portal account view. If no CEE is assigned, contact the Center that most closely aligns with the tariff number of your highest-valued commodity.

What if the refund already went to FedEx or UPS?

Three paths: a formal demand letter referencing the carrier's public pledge (after confirming the pledge covers your scenario), joining an active class action if your profile matches the class definition, or individual CIT litigation for past-deadline or larger exposures. Consult a licensed customs attorney for case-specific advice.

Can my broker still file CAPE Declarations on my behalf if I revoke their notify party designation?

Yes — but only if that broker was the licensed broker who originally filed the underlying entries, and they hold a valid Power of Attorney from you. CAPE filing rights are restricted to the IOR and the original filing broker. A broker added under a new Power of Attorney after the original entry filing cannot file CAPE for those legacy entries. If you have changed brokers since the entries were filed, your options are to file CAPE yourself as IOR, or to coordinate with the original filing broker.

Why does my broker appear as IOR on some of my entries?

A common reason is DDP (Delivered Duty Paid) Incoterm arrangements. Under DDP, the foreign seller technically takes on Importer of Record responsibility — but because most foreign sellers lack U.S. presence, they appoint a U.S.-based agent (often the freight carrier or licensed customs broker) to act as IOR on their behalf. The broker is then named on the CF-7501 as IOR, even though the legal responsibility traces back to the seller. Other common scenarios: parcel imports under Section 321 de minimis (suspended worldwide effective August 29, 2025 under Executive Order 14324), or specific historical arrangements with international carriers. If a broker is the IOR, only the broker (not the underlying customer) can file CAPE — and any refund routes to the broker first. See our DDP refund guide for the recovery options in this scenario.

Is paper Form 4811 still accepted?

Yes, but only the updated version 12/25. Previous versions are no longer accepted by CBP as of February 6, 2026. For adding or modifying notify parties, importers may either email the updated Form 4811 to their assigned CEE, or use the self-service Notify Parties tab in the ACE Portal. Revocation, however, can only be done by email to the CEE.

Can multiple notify parties be on file simultaneously?

Yes. Per CSMS #67648307, importers may have multiple notify parties on file in their ACE profile. Which notify party (if any) receives a refund for a specific entry is determined by what appears in box 28 of that entry's CF-7501.

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References

[REF 1] CBP — International Emergency Economic Powers Act (IEEPA) Duty Refunds — cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds

[REF 2] CBP — Centers of Excellence and Expertise Directory — cbp.gov/trade/centers-excellence-and-expertise-information/cee-directory

[REF 3] CSMS #67648307 — Updated Procedures to Add Notify Parties (CBP Form 4811). Two-condition rule, box 28 reference, two-method add/modify, email-only revocation. content.govdelivery.com/bulletins/gd/USDHSCBP-4083b33

[REF 4] CSMS #67190197 — ACE Portal Notify Parties Feature Deployment (December 22, 2025)

[REF 5] CSMS #68340863 — CAPE Refund Timing (60–90 day window)

[REF 6] CSMS #68536553 — Multiple ACE Reports for Monitoring CAPE Refund Claims (May 4, 2026)

[REF 7] CBP — ACE Portal Notify Party Information QRC — cbp.gov/document/guidance/ace-portal-notify-party-information-qrc

[REF 8] CBP Form 4811 — Special Address Notification (version 12/25)

[REF 9] FedEx — Navigating U.S. Tariffs and Customs Regulations — fedex.com/en-us/shipping/international/us-tariffs-impact.html

[REF 10] UPS — US Customs Tariff Refunds (UPS-as-IOR scope-limited pledge)

[REF 11] DHL — US Tariffs Global (carrier-as-IOR scope-limited pledge; customer-as-IOR self-exclusion) — dhl.com/global-en/microsites-2-0/core/us-tariffs.html

[REF 12] Holland & Knight — "CAPE Has Arrived: A Guide to Navigating the Next Phase of IEEPA Duty Refunds" (April 2026)

[REF 13] Troutman Pepper Locke — "CBP Issues Guidance on IEEPA Duty Refunds via New CAPE Process" (April 2026). ACH refund enrollment separate from duty-payment ACH.

[REF 14] Davis Wright Tremaine — "CBP to Deploy IEEPA Duty Refund Claims System Next Week" (April 2026). Phase 1 80-day scope, PSC limitations.

[REF 15] Foley & Lardner — "What Every Multinational Should Know About Filing for IEEPA Refunds Using CAPE" (April 2026). PSC excluded from IEEPA refunds; CAPE exclusivity.

[REF 16] Neville Peterson LLP — "IEEPA Refund Litigation Update and Considerations Regarding CBP's CAPE System" (April 2026). PSC before CAPE for non-IEEPA corrections; protective protest strategy.

[REF 17] Arnold & Porter — "The Next Wave of Tariff Litigation: Consumer Class Actions" (March 2026)

[REF 18] Covington & Burling — "Consumer Class Actions Arising from IEEPA Tariff Refund Efforts" (March 2026)

[REF 19] Sullivan & Cromwell — "Tariff Refund Claims Spur Litigation, Potential Deals" (March 2026)

[REF 20] Hinshaw & Culbertson LLP — Q&A on CAPE Filing Authority (April 2026)

[REF 21] 19 CFR § 24.72 — Claims; Set-off — law.cornell.edu/cfr/text/19/24.72

[REF 22] 19 CFR § 101.10 — Centers of Excellence and Expertise

[REF 23] 19 U.S.C. § 1514 — Protests (180-day post-liquidation window)

[REF 24] FR Document 2025-24171 — Electronic Refunds Interim Final Rule (February 6, 2026)

[REF 25] Executive Order 14324 — Suspending Duty-Free De Minimis Treatment for All Countries (effective August 29, 2025)

[REF 26] Great Lakes Customs Law — IEEPA Tariff Refund Guide (April 2026). Drawback exclusion from CAPE Phase 1.

[REF 27] Internal — REV-603, REV-613, and REV-615 reports guide

[REF 28] Internal — ES-022 vs ACH deposit reconciliation guide