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Trade & Business LawMarch 25, 20266 min read

CBP's CAPE Portal for IEEPA Tariff Refunds: What the Four-Step Process Actually Means

CBP says it is building an online portal to process IEEPA tariff refunds. The portal is not ready. It may not be ready for months. Here is what you should be doing right now.

U.S. Customs and Border Protection has publicly announced a forthcoming Customs Automated Processing Environment (CAPE) portal that, in theory, will let importers submit IEEPA refund claims through a four-step online workflow. The agency has not published a launch date. Internal guidance indicates the build is still in scoping. Treating the portal as the plan is a mistake.

The four steps CBP has described

  • Identify affected entries — the importer certifies which entry summaries contain IEEPA duty lines.
  • Upload supporting documentation — commercial invoices, entry summaries, proof of payment.
  • CBP reviews and adjudicates — timeline undefined, with no statutory deadline for CBP action.
  • Refund issuance — pathway for interest accrual and offset is not yet specified.

Why waiting for the portal is risky

The 300-day post-summary correction window and the 180-day protest window run regardless of whether CBP's portal is live. If the portal launches in Q3 2026 with a six-month claim window, a large share of 2022 and 2023 entries will already be time-barred. Importers who file now under existing pathways preserve optionality — they can still use the portal later if it turns out to be favorable.

What to do this quarter

  • Pull your ACE entry history for all IEEPA-affected entries since 2022.
  • Flag unliquidated entries — these are still eligible for PSC, the lowest-cost pathway.
  • For liquidated entries within 180 days, file protective protests before the window closes.
  • For entries outside both windows, evaluate CIT action with admitted trade counsel.

The CAPE portal may eventually make life easier. It will not undo a missed deadline.

TariffAuditLabs is a tariff recovery service, not a law firm. We prepare Post Summary Corrections and CBP protests and file them through your licensed customs broker. For Court of International Trade matters, we refer clients to independent CIT-admitted trade counsel; those engagements are contracted and priced directly with counsel and we do not share legal fees. This article is general information about IEEPA refund recovery and is not legal advice for any specific importer. Deadlines vary by entry; confirm your position with qualified counsel before relying on anything here.

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