In this article, learn about:
Basics of the CAPE Portal
What Phase 1 of tariff refunding entails
The crucial data quality requirements for refunds
As of 8 a.m. ET on April 20, 2026, the CAPE (Consolidated Administration and Processing of Entries) portal is live. For supply chain, finance, and operations leaders at brands and suppliers that import goods, this is the moment the question shifts from "if" to "how fast."
U.S. Customs and Border Protection (CBP) has opened the CAPE portal as the official and exclusive mechanism for recovering duties paid under IEEPA (International Emergency Economic Powers Act) tariffs, following the U.S. Supreme Court's February 2026 ruling. The window is open. The clock is running.
For organizations that built clean data infrastructure and maintained disciplined EDI (Electronic Data Interchange) records through the tariff period, this is a recoverable opportunity. For organizations that absorbed tariff costs informally, handled them outside their ERP, or have gaps in their B2B transaction history, Phase 1 of this process carries real risk of filing errors, rejection, and missed recovery.
This article covers what you need to know operationally, what Phase 1 does and does not cover, and what finance and supply chain teams should do before submitting.
Related Reading: CBP’s CAPE Declarations Portal Guide
What Is the CAPE Portal and Who Can File?
The CAPE portal is the exclusive channel CBP has designated for IEEPA duty refund claims. PSC (Post Summary Correction) filings cannot be used for this purpose. If your organization attempts to file refund claims through any mechanism other than CAPE, those claims will not be accepted.
Two parties are authorized to submit a CAPE Declaration:
Importer of record (IOR) on the original entry
Licensed customs broker (LCB) who filed the entries on the IOR's behalf
No other parties can file. If your organization was not the IOR and does not have a licensed customs broker relationship tied to the original entries, you will need to work through your broker before any submission can occur. Finding the IOR is sometimes half the battle.
Additionally, FedEx has announced that they will be submitting claims and issuing refunds to customers who paid these duties through them in instances when they were listed as the official IOR.
Filers must have an active ACE (Automated Commercial Environment) portal account with ACH (Automated Clearing House) banking information on file before submitting. Refunds cannot be issued without it. Organizations without an ACE account or without banking information registered should treat that setup step as an immediate priority. As of April 14, 2026, more than 56,000 importers had completed ACH registration, a prerequisite for receiving funds electronically.
What Does Phase 1 Cover, and What Does It Exclude?
Phase 1 covers two categories of entries:
Unliquidated entries (those not yet finalized by CBP)
Entries liquidated within the 80 days prior to the CAPE portal launch
Additional phases are planned to address the remaining entries, but no schedule has been announced. Entries liquidated beyond 80 days are not eligible in Phase 1. These entries will need to wait for phase guidance that does not yet exist.
The practical implication: assuming full eligibility across your import history is a planning error.
The scale of what CBP is administering helps explain why the process is phased. CBP processed approximately $166 billion in IEEPA duties across 53 million entries from more than 330,000 importers. Processing that volume under existing procedures would have required more than four million working hours, a figure CBP itself cited in its court filings when requesting time to develop a new approach.
Refunds will be consolidated by IOR and liquidation date. They are not issued on an entry-by-entry basis. Finance teams planning cash flow around refund timing should plan accordingly, with receipt estimated at 60 to 90 days after CAPE Declaration acceptance, not after submission.
Why Does Data Quality Determine Refund Speed?
The CAPE Declaration is a CSV upload containing entry numbers. That is the technical requirement. The operational challenge is everything that precedes it.
A CAPE Declaration can include up to 9,999 entry numbers. Any formatting error or an incorrect entry number results in rejection. Rejected declarations require resubmission. There is no partial acceptance. CBP's published guidance makes clear that ACE will run two rounds of validation: one on the declaration file itself, and a second on the individual entry numbers listed.
Trade advisors have noted that while CAPE is straightforward to submit, back-end scrutiny is not relaxed. As one director of global trade advisory services observed in Supply Chain Dive's coverage of the launch: the system is designed to get filings in the door quickly. What happens on the back end is a separate question. The accuracy of what you submit determines how quickly your refund clears.
This means that before your organization submits anything, you need to be able to:
Identify every entry number associated with IEEPA-affected imports
Confirm that each entry falls within Phase 1 eligibility criteria
Match entry records to the correct IOR on file
Validate that the HTSUS (Harmonized Tariff Schedule of the United States) classifications on those entries are accurate and reconciled to your product data
Organizations with complete purchase order, ASN (Advanced Ship Notice), and invoice records reconciled at the SKU and entry level and maintained in a connected EDI environment are in a strong position to build this list accurately. Organizations that managed tariff surcharges as line-item adjustments outside their core transaction records, or handled them in spreadsheets disconnected from their B2B data flow, will face a data assembly problem before they can begin filing.
Several months ago, the question was whether your organization had the data infrastructure to prove what it was owed if refunds came. That was speculative. The window is now open, and the reconciliation work that seemed theoretical is now a prerequisite for filing.
What Do Your Trading Partner Relationships Mean for Recovery?
This is where supply chain connectivity becomes a direct financial variable.
If your organization imports under private label arrangements, works through third-party sourcing agents, or relies on contract manufacturers who manage the customs entry process, the IOR on record may not be your organization’s legal entity. In those cases, your organization may not be the authorized filer under CAPE, and recovery depends on coordination with the party who is.
For suppliers selling to major retailers, the downstream effect of refund recovery also matters. Tariff costs that were passed through to retail buyers as pricing adjustments during the impact period may need to be revisited once refunds arrive. Retailers with strong supplier data visibility will have the documentation trail to identify which SKUs were affected, at what cost, and for what period.
Buyers and merchants with clean, granular trading partner data, including historical purchase order records tied to specific import entries, are in a better position to have those conversations with precision rather than estimates.
A PSC was previously a common tool for adjusting entry data after the fact. For IEEPA refunds, that mechanism is explicitly unavailable. The accuracy of the original entry data your broker filed is what the CAPE Declaration draws from. If those records contain errors, the path to correction runs through CBP's standard protest process, not CAPE.
What Should Operations and Finance Teams Do Before Filing?
Before submitting a CAPE Declaration, work through the following:
Account setup
Confirm your organization has an active ACE portal account
Verify ACH banking information is current and correctly registered in ACE
Confirm your licensed customs broker has all entry records accessible and can compile a compliant CSV
Entry data validation
Pull all import entries from the IEEPA-affected period
Identify which entries fall within Phase 1 eligibility: unliquidated or liquidated within 80 days of April 20, 2026
Confirm your organization is the IOR on each entry, or identify the correct authorized filer
Reconcile entry numbers against purchase order, ASN, and invoice records in your B2B transaction history
Flag any entries where HTSUS classifications were updated, amended, or are in dispute
Finance planning
Model refund receipt timing at 60 to 90 days post-acceptance, not post-submission
Account for the fact that Phase 1 will not capture all eligible duties; build scenarios for subsequent phase timing
Document which tariff costs were absorbed versus passed through to trading partners, as this will inform how refunds are recognized
Risk review
Identify any entries where the IOR on record does not match your current legal entity structure
Flag any entries where your customs broker relationship has changed since the original filing
Review for any prior protest filings that could affect entry status
Align Your Data Before the Window Closes
The operational question is no longer whether refunds are available. It is whether your organization's data infrastructure can support an accurate filing within the Phase 1 window.
Organizations with complete, connected EDI records (purchase orders, ASNs, and invoices reconciled at the entry level and maintained through a trading partner network) are in the strongest position to file with confidence and recover faster.
There’s a lot to work through here, and it doesn’t all fall on one team.
SPS Commerce Fulfillment connects suppliers, retailers, and logistics partners through a single, integrated network, making it easier to access the B2B transaction history that matters right now. Whether your team is reconciling entry data for CAPE filing or preparing for the margin conversations that follow, the SPS Commerce trading partner network helps support the work behind the scenes.
