The Vision Council (TVC) has issued an update outlining the upcoming deployment of a new system by US Customs and Border Protection (CBP) designed to streamline the processing of certain duty refunds.
According to TVC, CBP will launch the Consolidated Administration and Processing of Entries (CAPE) system on April 20. The system is intended to automate and consolidate refunds of duties previously paid under the International Emergency Economic Powers Act (IEEPA).
The CAPE system is designed to remove IEEPA duty lines from eligible entries, recalculate duties as though they were never owed, and issue consolidated refunds rather than processing reimbursements on an entry-by-entry basis.
Under the new process, importers of record and brokers will be able to submit refund requests through the Automated Commercial Environment (ACE) portal using CSV file uploads. Each submission may include up to 9,999 entries per file, and multiple files are permitted. Submissions will undergo a 2-stage validation process, including both file-level and entry-level reviews. Entries that fail validation—such as those involving reconciliation, drawback, protests, certain antidumping or countervailing duty statuses, or those more than 80 days past liquidation—will be excluded from processing.
TVC notes that importers are advised to submit CAPE declarations prior to filing drawback claims and to avoid entries where sureties have paid IEEPA duties. For unliquidated entries, liquidation is expected to occur approximately 45 days after CAPE acceptance, unless otherwise extended or subject to review. Entries that have been liquidated but are not yet final are expected to be reliquidated on the next business day following acceptance.
Refunds issued through CAPE will be consolidated by importer or designated party and liquidation date; they will be distributed via automated clearing house (ACH) payments. These refunds may be offset against any outstanding CBP debts and could combine multiple declarations. Standard processing timelines for eligible entries are estimated at 60 to 90 days following CAPE acceptance, subject to review and US Treasury processing.
The update also outlines procedural considerations. Protests filed solely for IEEPA-related refunds may be withdrawn within 80 days of liquidation and resubmitted through CAPE. Post Summary Corrections (PSCs), however, cannot be used to request IEEPA refunds, though they should be filed before CAPE submissions if unrelated corrections are needed. Users will be able to monitor refund activity through the ACE Portal’s CAPE Refunds Trade Report, and ACH enrollment is required to receive payments without delay.
To access the CAPE system, users must have an active ACE account and enable the ACH Refund Authorization function.
TVC further notes certain limitations and potential risks: At launch, CAPE will apply only to entries that are unliquidated or not yet final within 80 days of liquidation. A future phase of the system may expand eligibility to final entries, though no timeline has been confirmed. Additionally, the update highlights the possibility of legal challenges to the court order mandating CAPE, which could delay or halt refund processing. In such cases, stakeholders may consider filing protests to preserve claims before entries become final.