For thousands of American importers, the promise of recovering billions of dollars in duties has become a critical lifeline in a tightening credit environment. As companies grapple with severe cash flow shortages, the anticipation surrounding IEEPA tariff refund claims has shifted from a legal victory to a matter of operational survival.
The scale of the financial recovery is immense. According to filings with the U.S. Court of International Trade (CIT), the U.S. Customs and Border Protection (CBP) has collected over $166 billion in tariffs from more than 330,000 importers of record via Cherry Bekaert. For many of these businesses, the delay in receiving these funds has created a precarious financial gap, leaving them desperate for the liquidity required to maintain daily operations.
The current crisis is the result of a protracted legal battle over the International Emergency Economic Powers Act (IEEPA). On March 4, 2026, the CIT ruled in the case of Atmus Filtration, Inc. V. United States, ordering CBP to immediately start issuing refunds of IEEPA tariffs to importers of record via Cherry Bekaert. Although the court’s order was clear, the administrative reality of processing hundreds of billions of dollars for hundreds of thousands of entities proved to be a significant technical hurdle for the U.S. Government.
The Struggle to Automate Billions in Refunds
The primary obstacle to the immediate release of funds has been the limitations of the Automated Commercial Environment (ACE), the primary system used by CBP to track imports and duties. In a declaration filed on March 31, 2026, Brandon Lord, the Executive Director of CBP’s Trade Policy and Programs Directorate, informed the court that system upgrades were underway to handle the “massive volume” of expected refund submissions via Cherry Bekaert.
To resolve this, CBP is developing a new functionality known as the Consolidated Administration and Processing of Entries (CAPE). Unlike previous methods that processed refunds on an entry-by-entry basis, CAPE is designed to consolidate refunds of IEEPA duties and associated interest to streamline the process via CBP.gov.
As of the March 31 update, CBP reported varying levels of completion across the four integrated components of the CAPE system: the Claim Portal is 85% complete, the Review and Liquidation/Reliquidation component is 80% complete, the Refund component is 75% complete, and the Mass Processing component is 60% complete via Cherry Bekaert.
CAPE Rollout: What Importers Need to Know
CBP has announced that the first phase of the CAPE process will launch on April 20, 2026 via CBP.gov. However, this initial launch will not cover all eligible importers. Phase 1 is strictly limited to certain unliquidated entries and specific entries that are within 80 days of liquidation via CBP.gov.
For those eligible in the first phase, the process for requesting refunds requires a specific set of actions. Importers of Record (IORs) and authorized Customs brokers must have an established ACE Secure Data Portal account and provide CBP with their bank account information through that portal via CBP.gov.
The actual filing of the refund request will be handled via a Comma-Separated Values (.CSV) file submitted through the ACE Portal. CBP has explicitly stated that the Automated Broker Interface (ABI) will not be used for these declarations via CBP.gov. Each individual CAPE Declaration is capped at a limit of 9,999 entries.
Summary of the CAPE Refund Process
| Requirement | Detail |
|---|---|
| Account Type | ACE Secure Data Portal account |
| Payment Method | Bank account information provided via ACE Portal |
| Submission Format | .CSV file (CAPE Declaration) |
| Submission Limit | Maximum 9,999 entries per declaration |
| Excluded Interface | Automated Broker Interface (ABI) |
The Complexity of ‘Unstacking’ Tariffs
Adding to the administrative burden is the complex process of “unstacking” tariffs. Under current CBP guidelines updated on February 4, 2026, certain products are exempt from multiple overlapping tariffs to prevent cumulative financial penalties via CBP.gov.
For example, semiconductors subject to Section 232 are not subject to IEEPA tariffs related to China, Canada, Mexico, Brazil, or Russian Oil via CBP.gov. Similarly, content subject to Section 232 Aluminum, Steel, or Timber/Lumber is not subject to IEEPA tariffs for Canada, Mexico, Brazil, or Russian Oil via CBP.gov.
However, these exemptions are not universal. Products containing a mixture of copper, steel, and/or aluminum continue to be subject to all applicable Section 232 tariffs via CBP.gov. This level of granularity explains why CBP has struggled to implement a rapid refund system; the government must verify the exact composition and regulatory history of millions of individual import entries before releasing funds.
Impact on the Global Supply Chain
The delay in these refunds has ripple effects beyond the balance sheets of individual companies. When importers are cash-starved, their ability to procure raw materials and maintain inventory levels is compromised, which can lead to increased costs for consumers and disruptions in the supply chain.
The legal tension remains high. While Senior Judge Richard K. Eaton has continued the pause on his original March 4 order for immediate refunds, this leniency is contingent upon CBP providing regular status updates on the CAPE functionality via Cherry Bekaert. Any further delays in the April 20 launch could potentially lead the court to impose stricter mandates on the agency.
For the 330,000 affected importers, the CAPE system represents more than just a technical upgrade—it is the only viable path toward recovering the billions of dollars in IEEPA tariff refund claims that are currently held by the U.S. Treasury.
The next critical checkpoint is April 20, 2026, when CBP is scheduled to launch Phase 1 of the CAPE functionality for eligible unliquidated entries. Importers are encouraged to verify their ACE Portal accounts and prepare their .CSV declarations in advance of the launch date.
Do you have questions about the CAPE rollout or how the unstacking provisions affect your business? Share your thoughts in the comments below or share this report with other industry professionals.