US Customs and Border Protection’s (CBP) filing with the US Court of International Trade (CIT) on March 6, 2026 stated that limitations within the Automated Commercial Environment (ACE) currently prevent the agency from complying with the court’s directive to liquidate and reliquidate IEEPA‑affected entries with refunds. CBP advised the court that it is developing new ACE functionality to address IEEPA‑related refunds and estimated that the required system enhancements could take approximately 45 days, subject to further court oversight.
In an update filed with the court on March 12, 2026, CBP advised that it is developing new functionality referred to as the Consolidated Administration and Processing of Entries (CAPE) system.
CBP has described CAPE as a new, web‑based claims portal within ACE intended to allow importers to submit refund requests for IEEPA duties through a mass‑processing approach. Under the framework described to the court, CAPE is expected to support the submission of a CAPE Declaration, consisting of a Comma‑Separated Values (CSV) file identifying entry numbers for which the importer is seeking an IEEPA refund.
According to CBP’s filing, ACE will perform file‑level and entry‑level validation on the submitted data. Entries that pass validation may then be processed to remove the IEEPA HTS duty lines and recalculate duties exclusive of IEEPA duties. CBP has indicated that accepted entries would then proceed through liquidation or reliquidation, as applicable, with the CAPE refund component designed to consolidate approved refunds for issuance.
CBP has also advised that not all entry types may be eligible for processing in the initial phase of CAPE, including entries subject to trade remedy proceedings, suspended or extended liquidations, foreign trade zone withdrawals, and drawback‑related entries.
CAPE is new functionality, and CBP has advised the court that its development is occurring in phases, with different components at varying stages of completion. At this time, CBP has not announced a firm date for when refund claims may be submitted or when refunds may be issued.
CBP has further advised that refunds will be issued electronically via ACH. Importers that have not already established ACH refund authorization in their ACE Portal account should take steps now to do so. Please refer to Mohawk Global’s ACE Portal FAQ Guide for additional information.
Mohawk Global will continue to monitor CBP filings and court updates regarding the IEEPA refund process and will provide further guidance as additional information becomes available.
What Importers Should Do Now
- Confirm entry data
Identify entries on which IEEPA duties were paid and confirm each entry’s liquidation status (unliquidated, liquidated but not final, or final), as refund eligibility is entry‑specific. - Ensure ACE Portal access
Verify that your company has an active ACE Portal account and that appropriate users have access to entry data and reports. - Set up ACH refund authorization
CBP has indicated that IEEPA refunds will be issued electronically via ACH. Importers that have not yet established ACH refund authorization in ACE should do so as soon as possible. - Retain supporting records
Maintain entry summaries, payment records, and duty calculations related to IEEPA duties, which may be needed to support refund claims or CBP validation. - Monitor liquidation deadlines
For entries that have liquidated or may liquidate while CBP finalizes its refund process, importers should remain mindful of protest deadlines and consult with counsel or advisors regarding protective actions. - Await further CBP guidance
CBP has advised that the CAPE refund process is being developed in phases. Importers should expect additional instructions from CBP before refund submissions can be made.
Mohawk Global Trade Advisors can help you uncover and act on your IEEPA refund opportunities with confidence. Our IEEPA Data Analysis Service quickly identifies where your real refund dollars are—by securely analyzing your ACE data, segmenting entries by liquidation status, quantifying financial impact, and clearly outlining prioritized next steps with expert guidance—so you can act confidently with minimal internal effort. Reach out today.