IEEPA and CAPE

What is CAPE?

CAPE is CBP's process for refunding IEEPA duty: the importer of record or its broker files a declaration in ACE, and CBP refunds the duty plus interest.

  • Filed by a licensed broker⁠†
  • Published fees, charged after CBP pays
  • Sealed on AMD SEV-SNP

How it works:

  • The declaration is a CSV file listing up to 9,999 entry numbers, uploaded under the CAPE tab of an ACE Portal account. It can't be sent through ABI.
  • Who files: only the importer of record or its filing broker; refund firms work through one of them.
  • Payment goes by ACH. Since February 6, 2026, receiving a refund requires an ACE Portal account and the ACH Refund application.
  • Phases decide which entries CAPE takes and when; see What do CAPE Phases 1, 2 and 3 cover?

The scale: about $166 billion of IEEPA duty was collected from about 330,000 importers, according to a CBP court filing of September 15, 2026.

By September 11, 2026, CBP had accepted about $134.7 billion into CAPE and certified about $122 billion to Treasury.

Am I eligible? Your entries decide: liquidation status, protests and entry type set each entry's phase.

We don't file CAPE; you or your filing broker does, and our sequencing check flags every entry with IEEPA duty first.

  • CBP CAPE guidance, via Troutman Pepper and Holland & Knight, 2026⁠[1]⁠[2]
  • Electronic Refunds rule, Federal Register, Jan 2, 2026⁠[3]
  • CBP court filing, Sept 15, 2026⁠[4]
  • CBP CAPE statistics, Sept 2026⁠[5]
Also asked
  • What is CAPE, and am I eligible?
  • What is the CAPE refund process?
  • How do I recover the IEEPA duties I paid?
  • What is an IEEPA tariff refund?
  • How exactly will the refund system work?
  • How many importers are impacted?

Written by the NexQloud Drawback team from the primary sources linked on this page.

Not legal advice. NexQloud Drawback is not a government agency.

NexQloud Drawback is software used by licensed customs brokers.

Related

IEEPA refunds, CAPE and drawback

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Run the demo on a sample file. About three minutes.

  1. 01

    Upload one quarter.

    Entry summaries, invoices and export records.

    WhoYou

  2. 02

    AI drafts your claim.

    It ties each export to its import, to the cent.

    WhoThe agent

  3. 03

    Your broker files. CBP pays you.

    The refund goes directly to your bank account.

    WhoA licensed broker

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IEEPA refunds

Got your IEEPA refund? Drawback is the one that repeats.

We check every entry for CAPE first, the order CBP recommends.⁠[6] Drawback can recur every year.

Which tariffs qualify?

Section 301 duties, the Section 122 surcharge and the Section 338 duties on Canada all qualify.⁠[7]⁠[8]⁠[9]

How CAPE and drawback fit together

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Brokers earn the drawback fee. CPA firms bill their own work. Refund firms keep their CAPE clients. Design partners help shape it before launch.

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Questions

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What is duty drawback?

A refund of up to 99% of the duties, taxes and fees you paid on imports that you later export or destroy, or that went into products you export.⁠[10] It works in any industry.

When can I start?

We open to importers in waves, in the order of the waitlist. The demo shows the whole product with sample data today, and partners can apply now.

What will you need from me?

One quarter of records to start: entry summaries, invoices, packing lists, shipping documents, and export, return or destruction records.

How long until CBP pays?

With accelerated payment, CBP can pay before the claim is final. Its only published timing, from December 2018: processing "will generally take place within 3 weeks of the claim resubmission date."⁠[11]

Can I use my own customs broker?

Yes. Invite your own broker, or use one we name before you sign. Your POA stays with your broker, and your broker sets its own fee.

What if CBP pays less than claimed?

The fee follows what CBP actually pays. If CBP later recovers part of a payment, the fee is reduced to match.

Do you file CAPE claims?

No. We check every entry for CAPE first and flag what belongs there. You or your broker files CAPE. Refund firms work through one of you.

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