Authored by Baker Tilly’s Tosca Derrick
Billions in potential tariff refunds are moving closer to reality, but not all importers will benefit at the same time.
A March 31, 2026, declaration filed with the U.S. Court of International Trade (CIT) lays out how U.S. Customs and Border Protection (CBP) plans to begin processing refunds tied to tariffs imposed under the International Emergency Economic Powers Act (IEEPA). This latest CBP guidance on tariffs provides the clearest signal yet on what will be recoverable now, what will take longer and where companies may face limitations.
At the center of the effort is a new system capability within the Automated Commercial Environment (ACE), known as the Consolidated Administration and Processing of Entries, or CAPE. This system is being built to handle refund claims at scale, introducing new processes that will directly affect how and when importers can recover duties.
For companies navigating IEEPA exposure, the message is clear. Opportunity is emerging, but it will require a targeted, well-timed approach.
A system under construction with real financial impact
The declaration confirms that CBP is building CAPE as a multi-component solution designed to handle the scale and complexity of IEEPA-related refunds. These components include a claim portal, mass processing engine, review and reliquidation functionality and a refund module.
Progress is advancing, but the system is not fully there yet. The claim portal is nearing completion at about 85%, while mass processing is still developing at around 60%. The review and liquidation component is further along at roughly 80%, with refund functionality close behind at about 75%.
That uneven progress is important. It signals that while the infrastructure is coming together, not every refund scenario will be supported at launch. Instead of a single, fully functional release, importers should expect a phased rollout that expands over time.
Phase one: limited scope, immediate opportunity
CBP’s initial rollout of CAPE will focus on a narrower set of entries. In phase one, the system will handle unliquidated entries as well as those still within the 90-day voluntary reliquidation window.
Together, those categories represent roughly 63% of entries impacted by IEEPA duties, meaning most refund opportunities will be accessible early, but not all.
However, the system will not initially process entries where liquidation is final. Those cases are deferred to future phases, creating a gap that many importers will need to actively manage through other legal or administrative avenues.
From a strategic perspective, this creates a clear prioritization framework. Companies should focus first on entries still within actionable timelines, where recovery is most immediately achievable.
Importantly, refunds will not be issued automatically. Importers will need to take action through CAPE to initiate and support claims.
Refund mechanics are changing: digital is now mandatory
As part of evolving CBP guidance on tariffs, one of the more operationally significant updates is the shift to fully electronic refunds. As of February 2026, CBP requires that all refunds be issued via electronic funds transfer, with limited exceptions.
The scale of readiness is notable. More than 26,000 importers of record have already enrolled, representing approximately 78% of impacted entries and more than $120 billion in associated duty value.
For companies that have not yet completed enrollment, this is a critical dependency. Without proper setup, even approved claims may face delays in disbursement.
What CAPE will and will not handle in early stages
Phase one introduces some important nuances in how entries will be handled. In certain cases, IEEPA duties will be removed and recalculated, but refunds will not be issued right away. Instead, those entries will move through the normal liquidation process, with refunds issued at that point.
Other categories bring additional complexity. Entries tied to antidumping or countervailing duties may remain suspended until the Department of Commerce provides liquidation instructions. Warehouse entries will also continue to follow standard timelines, meaning refunds will not be immediate even after adjustments are made.
At the same time, some entries are excluded from phase one altogether. These include reconciliation entries, drawback claims, entries under active protest and certain AD/CVD cases that are already pending liquidation instructions.
Taken together, these limitations make it clear that CAPE is not yet a universal solution. Importers with more complex entry profiles will need to take a more tailored approach to recovery.
Timing expectations and compliance considerations
CBP has indicated that processing of accepted claims may take up to 45 days, particularly where additional validation or compliance review is required. This reflects a broader reality. Both system rollout and refund execution are expected to follow staged timelines rather than immediate payouts.
That distinction matters. While CAPE is being built to facilitate refunds, it is also designed with stronger validation and review controls. Enforcement remains a priority alongside recovery.
In practice, that means claims need to be accurate, complete and well supported from the start. Data integrity within ACE filings will be closely reviewed, and even small inconsistencies can slow processing or delay payment.
Looking ahead: expanded capabilities, increased complexity
Future phases of CAPE are expected to expand beyond the initial scope and address more complex scenarios. These include entries with final liquidation, reconciliation and drawback claims, complex interest calculations and enhanced compliance and financial controls.
As these capabilities are introduced, access to refunds will broaden. At the same time, the technical and regulatory complexity of the process will increase, requiring more sophisticated coordination across trade, finance and compliance functions.
What this means for importers now
The declaration underscores a critical point. Refund recovery tied to IEEPA tariffs is no longer theoretical. It is operational, but not yet comprehensive.
Organizations should act now, focusing on a few key priorities:
- Identify eligible entries within the current processing scope.
- Validate ACE data and entry classifications.
- Complete electronic refund enrollment requirements.
- Develop a phased recovery strategy aligned to CAPE rollout.
At the same time, timing considerations remain critical. Not all entries will be addressed in the initial phase of CAPE, and certain refund opportunities may depend on actions taken outside of the system.
Importers should evaluate whether filing protests is necessary to preserve potential refund claims, particularly for entries approaching liquidation deadlines or those that may fall outside the initial scope of CAPE processing. Acting sooner rather than later can help preserve flexibility and avoid unintended loss of recovery opportunities as CBP guidance continues to evolve.
A strategic moment for trade leaders
The development of CAPE reflects a broader shift in how trade enforcement and revenue recovery are administered. It combines automation, large-scale data processing and evolving legal requirements into a single operational framework.
For importers, success will depend on more than awareness. It will require coordination across trade compliance, finance and legal teams, along with a clear understanding of where opportunities exist today and where they will emerge next.
As CBP guidance on tariffs continues to evolve alongside CAPE development, organizations that act early and prepare thoroughly will be best positioned to recover value efficiently and avoid unnecessary delays. Baker Tilly continues to monitor these developments and works with clients to translate evolving requirements into practical, actionable strategies.
Ready to evaluate your refund opportunity?
As the refund process moves from legal ruling to administrative execution, the challenge for importers is no longer just eligibility. It is execution. IEEPA tariff refunds will depend on complete and accurate data, defensible methodologies and the ability to navigate evolving CBP requirements. In practice, that means organizing years of entry data, validating duty payments and aligning documentation with how claims will be reviewed. Even where refunds are clearly owed, outcomes will be shaped by how well claims are prepared and submitted.
Baker Tilly’s tariff refund and recovery services are designed to help organizations move from eligibility to execution. This includes assessing refund exposure, identifying eligible entries and building claim packages that can stand up to CBP review.
That work often cuts across multiple functions. Entry-level data needs to be compiled and validated across systems; refund calculations must be consistent, supportable and documentation has to align with how CBP evaluates claims. At the same time, organizations must manage filings and timelines while also considering downstream tax and financial reporting impacts.
This level of coordination reflects a broader reality. Legal entitlement alone does not guarantee recovery. Execution, documentation and timing ultimately determine outcomes.
As CAPE continues to evolve and refund pathways expand, organizations that act early and prepare thoroughly will be better positioned to recover value efficiently and avoid unnecessary delays.
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