Whether you’ve already filed for IEEPA refunds—or assume this doesn’t apply to you—there’s a gap in how the CBP CAPE system is actually working right now.
Most companies think:
“We submitted. Now we wait for the refund.”
That is not how this process is behaving in practice.
CBP’s IEEPA refund system has been live for two weeks. The early data shows a pattern that should concern every importer—whether you’ve filed or not.
What the first week of CAPE data actually shows
On April 20, CBP launched CAPE — the Consolidated Administration and Processing of Entries system.
Within six days:
Over 75,000 declarations were submitted
Covering more than 11.2 million individual entries
Only 1.74 million entries cleared all validations
That’s a clearance rate of roughly 15%.
The remaining 85% are not rejected. Not approved. Simply unresolved.
And unless you are actively reviewing your Validation Result File in ACE, you likely have no visibility into where your entries stand.
What CAPE does — and what it doesn’t
CAPE is a processing mechanism, not a compliance audit.
When you upload a CSV of entry numbers through ACE, the system runs validation in two stages:
Declaration-level checks (formatting, authority, duplicates)
Entry-level checks (existence in ACE, HTS code presence, prior declaration conflicts)
What it does not do:
Verify that your entry set is complete
Check whether your entries fall within the correct eligibility window
Resolve conflicts across multiple brokers
Correct underlying data issues
Validation ≠ eligibility. Acceptance ≠ approval.
Most failures happen after the file is accepted.
The CAPE refund process — four separate steps
Declaration accepted (format, authority, duplicates)
Entry-level validation — where most failures occur
CBP review and reliquidation (60–90 days)
Payment issued via ACH
Each step is independent. Passing one does not guarantee progress to the next.
What this means for your refund exposure
To make this concrete:
If your company paid $500,000 in IEEPA duties and submitted 100 entries to CAPE—
but only 15 cleared validation—you are currently on track to recover roughly $75,000.
The remaining $425,000 is sitting in an unresolved state.
This gap is not primarily due to ineligibility.
It’s driven by submission issues the system does not correct on your behalf.
Most importers are recovering a fraction of what they are owed—not because their claims are invalid, but because their inputs are incomplete or misaligned with CAPE’s rules.
This gap is often recoverable—if you can identify where entries are stalled.
Use our IEEPA refund calculator to surface eligible entries and pinpoint what’s still stuck before the window closes.
Who is most exposed right now
Not all importers face the same level of risk. The current validation failure pattern disproportionately affects:
Importers working with multiple customs brokers
Entry duplication across declarations can permanently exclude entries from Phase 1.
Companies with long or mixed entry timelines
Submitting full historical data without filtering for the 80-day eligibility window leads to silent validation failures.
Importers who filed immediately after CAPE launched
Early submissions were often made without full clarity on validation behavior or system constraints.
High-volume importers
The larger the entry set, the higher the probability of mismatches, duplicates, and eligibility gaps.
If you fall into any of these categories, the likelihood that a significant portion of your entries are unresolved is materially higher.
Three reasons refunds are being blocked
These failures are not random. Three issues account for most blocked entries:
1. Phase 1 eligibility window mismatch
Phase 1 covers only:
Unliquidated entries
Entries liquidated within 80 days of submission
Entries outside this window fail silently at validation.
Action: Filter by liquidation date before building your CSV.
2. Duplicate entries across declarations
Each entry number can appear on only one accepted declaration.
If duplicates exist across brokers or submissions:
The entry is locked out of Phase 1
There is no amendment path
Action: Consolidate and deduplicate across all brokers before filing.
3. Missing ACH setup
CBP no longer issues paper checks.
If ACH is not configured in ACE, payment cannot be issued—even if everything else succeeds.
Action: Ensure ACH is enrolled before relying on any refund timeline.
Two deadlines most importers aren’t tracking
Two external pressures are narrowing the window for effective action:
Phase 1 eligibility window
The 80-day window advances daily. Entries eligible today may age out if filing is delayed.
Government appeal deadline — early June 2026
A successful appeal could pause or restructure the refund process.
These do not require rushing a flawed submission.
They do require prioritising a complete and accurate one now.
What to do if you haven’t filed
Speed is less valuable than accuracy.
A flawed declaration cannot be amended for affected entries.
What to do if you’ve already filed
Do not assume a confirmation means your refund is progressing.
Review your Validation Result File in ACE:
Identify which entries cleared validation
Isolate failures and error codes
Determine which entries can still be resubmitted
If multiple brokers were involved, confirm that no entries were duplicated across declarations.
What happens next
CAPE is still in its early phases, but its structure is unlikely to change fundamentally.
Future phases may expand eligibility to more complex entry types, but they will not resolve underlying data issues retroactively. The system is designed to process what is submitted—not to reconcile inconsistencies across filings.
Importers who treat this as a data integrity and coordination problem—not just a filing exercise—will be in a materially stronger position as additional phases roll out.
How Airlift approaches this
We are a licensed NVOCC and customs broker. Entry data management, ACE coordination, and compliance are core to what we do.
The IEEPA refund process is effectively a large-scale entry audit:
Verifying eligibility
Resolving cross-broker conflicts
Ensuring payment prerequisites are in place
At this point, you have two options:
You can work through this process internally—auditing entries, reviewing validation results, and reconciling data across brokers.
Or you can use our IEEPA refund checker:
Upload CBP Form 7501s
Identify eligible entries
Flag broker conflicts
Estimate recoverable duties in under a minute
For full pre-filing audits, our compliance team handles the process directly.
Either way, the time to act is before the Phase 1 window narrows further—not after.
Frequently asked questions
What is CAPE?
CBP’s system for processing IEEPA refund claims through ACE using consolidated declarations.
Why are entries failing validation?
Primarily due to eligibility window mismatches, duplicate entries, and missing payment setup.
How long do refunds take?
Typically 60–90 days after successful validation and review.
Can declarations be amended?
No. Entries on accepted declarations cannot be refiled in Phase 1.
Final takeaway
Most importers are not being denied refunds.
They are failing to reach the stage where refunds can be issued.
That distinction is where the risk—and the opportunity—sits right now.