CBP’s Claims Adjudication and Processing Engine (CAPE) is expected to launch approximately mid-April 2026. China importers — who hold the largest per-company exposure due to stacked rates up to 145% — should prepare now. Having validated, complete data ready for day-one filing positions you ahead of 330,000+ other importers competing for limited CBP processing capacity. For details on what records to gather, see the documentation guide.
Step 1: Verify ACE Secure Data Portal access
Log into the ACE Secure Data Portal at ace.cbp.dhs.gov. If you have never accessed ACE directly (your customs broker handles it), you will need to request an account. Account provisioning takes 5–10 business days.
Navigate to the “Reports” tab. You need access to the Entry Summary Report (ES-003) and the Statement Reports. If your account does not show these reports, contact the ACE Help Desk at (866) 530-4172 to request the appropriate access role. Your broker can also pull these reports on your behalf if you authorize them, but having direct access ensures you can verify data independently.
Step 2: Export your ES-003 for the full covered period
The covered period for IEEPA tariff refunds runs from February 4, 2025 (the effective date of Executive Order 14195) through February 24, 2026 (four days after the Supreme Court ruling, allowing for in-transit entries).
In ACE, set your date range to cover this full window. Export the complete report — do not filter by HTS code at this stage. You need the raw data to identify all entries that may carry IEEPA line items, including entries where IEEPA was one of several duty programs applied.
The ES-003 contains entry number, entry date, HTS codes, duty amounts, and liquidation status for every entry filed under your IOR number. This is the foundational document for your refund claim.
Step 3: Identify all IEEPA-specific HTS codes
Review your ES-003 for entries containing any of these HTS codes:
- 9903.01.20 — Fentanyl tariff, initial 10% (effective February 4, 2025)
- 9903.01.24 — Fentanyl tariff, additional 10% (effective March 4, 2025)
- 9903.01.25 — Reciprocal tariff, 34% (effective April 2, 2025)
- 9903.01.63 — Reciprocal tariff, additional 91% (effective April 9, 2025)
A single entry may contain multiple IEEPA HTS codes. An entry filed on April 10, 2025 could show all four codes — both fentanyl layers and both reciprocal layers — for a combined 145% IEEPA rate on that entry. Every dollar associated with these codes is refundable.
Step 4: Separate IEEPA entries from Section 301 entries
This is the most critical preparation step and the one most commonly done incorrectly. China importers typically paid both IEEPA tariffs and Section 301 tariffs on the same goods. Only IEEPA is refundable under the Supreme Court ruling.
Section 301 tariffs appear under HTS 9903.88.xx codes. These are NOT refundable now — they were imposed under different legal authority (Trade Act of 1974, Section 301) and are subject to separate, ongoing litigation. For a detailed breakdown, see the Section 301 vs. IEEPA comparison and our FAQ.
On a single CF-7501 entry summary, you may see both 9903.01.xx (IEEPA, refundable) and 9903.88.xx (Section 301, not refundable) line items. Your CAPE declaration must include only the IEEPA amounts. Submitting Section 301 amounts in an IEEPA refund claim will cause the declaration to be returned for correction, costing you weeks of processing time.
Step 5: Enroll in ACH electronic refunds
CBP no longer issues paper refund checks. All CAPE refund disbursements will be processed via ACH direct deposit. If your company is not enrolled in ACH with CBP, enroll now.
In ACE, navigate to Account Management and verify your banking information. If your bank account has changed since your last interaction with CBP, update it immediately. ACH enrollment verification takes 3–5 business days. A stale or incorrect bank account will delay your refund disbursement even after your declaration is approved.
Step 6: Check liquidation statuses and protest deadlines
Entries have a 180-day protest window after liquidation. If any of your IEEPA-period entries have already been liquidated, check whether the protest deadline has passed or is approaching.
For liquidated entries nearing the 180-day mark, file a protest immediately to preserve your refund rights. Your customs broker can file a protest through ACE. Do not wait for CAPE — a missed protest deadline extinguishes your claim permanently.
For entries that are still unliquidated (suspended), you have more time, but you should still include them in your CAPE declaration when the portal opens.
Step 7: Validate your data before CAPE opens
CBP has approximately 2,500 staff to process an estimated 53 million entry lines from 330,000+ importers. Processing will be sequential — declarations filed first will likely be processed first. But filing fast with bad data is worse than filing correctly one week later.
A returned declaration goes to the back of the queue. An incomplete or incorrectly separated claim (mixing IEEPA and Section 301 amounts) will be rejected and must be resubmitted. Having clean, validated, properly separated data means your declaration processes smoothly on first submission.
Request a free Impact Assessment to validate your data before CAPE opens. The assessment identifies every IEEPA entry, separates IEEPA from Section 301, matches each entry to the correct rate, and calculates the precise refundable amount. For the complete rate escalation from 10% to 145%, see the China IEEPA rate timeline.
The alternative to waiting for CAPE
If the CAPE timeline is a problem for your business — or if you need capital before mid-April — claim assignment delivers funds in 48 hours regardless of CBP queue position. You sell your refund claim to a qualified buyer at a discount and receive immediate payment.
This is not an either/or decision. Many importers assign their highest-value claims for immediate capital and file remaining claims through CAPE for full recovery. Firms like tariffresolution.com and tariffbuyouts.com specialize in China IEEPA claim assignments.
FAQ
Q: What happens if CAPE launch is delayed beyond mid-April 2026? A: CBP has not committed to a firm date. If the portal launch slips, importers who have already prepared their data lose nothing — the preparation work applies regardless of when CAPE opens. Importers who need capital before CAPE launches can pursue claim assignment in the interim.
Q: Can my customs broker file through CAPE on my behalf? A: CBP has indicated that licensed customs brokers will be able to submit declarations on behalf of their clients through CAPE. However, you should still verify your ACE access and banking information independently, as the broker will need your authorization and validated data.
Q: What if some of my entries are liquidated and some are still suspended? A: Both liquidated and unliquidated entries are eligible for IEEPA refunds. For liquidated entries, ensure you are within the 180-day protest window. For unliquidated entries, include them in your CAPE declaration. Your assessment should flag any entries with approaching deadlines.