CAPE IEEPA refunds: what ACE still excludes (including finally liquidated)

CAPE (Consolidated Administration and Processing of Entries) is CBP's ACE Portal path for IEEPA duty refund declarations. Phase 1 launched April 20, 2026. The July 10, 2026 Trade Information Notice is still the clearest primary checklist of what ACE will process and what it will refuse.

If your portfolio includes finally liquidated entries, open protests, drawback-claimed entries, or warehouse 21/22, do not expect CAPE to swallow them today. Prep the eligible pool, enroll ACH refunds, and keep excluded buckets in a separate workstream.

CAPE still excludes finally liquidated entries. File the eligible CSV through the ACE Portal CAPE tab, not ABI.

How CAPE intake works

• File a CSV CAPE Declaration via the ACE Portal CAPE tab (Importer, Organizational Broker, or Filer sub-accounts). ABI cannot file CAPE Declarations.
• Max 9,999 entries per file; submit multiple declarations if needed. Template download sits under the Upload control.
• Only the IOR for the listed entries, or the customs broker that filed those entries for the IOR, may submit.
• For valid entries, ACE strips dutiable IEEPA Chapter 99 codes/duties, versions the entry summary, then (after CBP review) liquidates or reliquidates and issues consolidated refunds.

What CAPE processes now

Per the TIN, CAPE currently processes most entries that are unliquidated or up to 80 days past liquidation. That includes entries flagged for reconciliation (types 01, 02, 06) when the type 09 reconciliation is not yet on file, and warehouse withdrawal types 31, 32, 34, and 38. Entries with liquidation status suspended, extended, or under review can also move through; they keep that status until resolved, with any validated refund issued after liquidation.

What ACE still will not accept

• Finally liquidated entries: still out of scope on the July TIN. Inventory them separately; do not burn CAPE validations hoping ACE will override finality.
• Open protests / drawback claims: close or resolve the conflicting claim path before CAPE, or keep those entries off the CSV.
• Warehouse 21/22: withdrawals (31/32/34/38) can process; the underlying warehouse entries cannot.
• AD/CVD pending DOC liquidation instructions: wait for the statutory liquidation path to clear.

CBP's IEEPA refunds page states CAPE is rolling out in phases (Phase 1: certain unliquidated / within-80-days entries; Phase 2: reconciliation-flagged entries without type 09 on file). Trade reporting anticipates further phases for more complex buckets, including finally liquidated plaintiff entries. Until CBP publishes a CSMS, CBP.gov update, or court filing you can cite for a go-live date, treat finally liquidated entries as excluded and prep them offline.

Prep checklist

• 1. Segment entries: CAPE-eligible vs. excluded (final liquidation, protest, drawback, 21/22, AD/CVD-pending, etc.).
• 2. Enroll ACH refund banking in the Importer sub-account (ACH Refund Authorization). Refund ACH is separate from payment ACH.
• 3. Confirm submitter identity: IOR or the filing broker for those entries.
• 4. Build CSVs at or under 9,999 entries; use the Portal template; no ABI shortcut.
• 5. Monitor with ACE Reports: ES-003 (line tariff / IEEPA indicator), ES-022 (CAPE entry summary), REV-603 (trade refund statuses), plus REV-613 / REV-615 as needed.

This article is for general information and is not legal or tax advice. Drawback eligibility depends on your specific facts, and final refunds are determined by CBP at liquidation. Consult a licensed customs broker or attorney for your situation.