CBP’s CAPE refund tool goes live April 20, 2026. Here’s how 3PLs, customs brokers, and ecommerce operators can help importers of record claim IEEPA tariff refunds through the ACE Portal and why most won’t without action this week.
IEEPA tariff refunds are reimbursements being issued by U.S. Customs and Border Protection (CBP) to importers of record who paid tariffs under the International Emergency Economic Powers Act between February 4, 2025 and February 24, 2026. The U.S. Supreme Court ruled these tariffs unlawful in February 2026. Refunds are processed through the ACE Portal’s new CAPE module and require importers to have valid U.S. bank account information on file.
| 53MEntries affected | ~300KImporters impacted | 60–90Days to refund |
What Happened: The IEEPA Ruling, Explained
In February 2026, the U.S. Supreme Court ruled that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) were unlawful. CBP stopped collecting these tariffs on February 24, 2026, and refunds are now flowing back to affected importers through the Automated Commercial Environment (ACE) Portal.The ruling specifically covered the “reciprocal” tariffs and “fentanyl-related” duties imposed between early 2025 and February 2026. The decision did not affect Section 301 tariffs on Chinese goods or Section 232 duties on steel, aluminum, and auto parts. Those remain in full effect, and any merchant-facing guidance should make that distinction clear.
| THE SHORT VERSION •IEEPA tariffs struck down by the Supreme Court (Feb 2026) • Collection ended Feb 24, 2026 • Eligible entries: Feb 4, 2025 – Feb 24, 2026 • Refunds flow only through the ACE Portal (CAPE module)• Section 301, 232, and new Section 122 (10%) are unaffected |
Who Qualifies for an IEEPA Tariff Refund?
An importer is likely eligible for an IEEPA tariff refund if all three conditions are met:
- Importer of record: They were listed as the importer of record (IOR) on shipments that entered the U.S. between February 4, 2025 and February 24, 2026.
- Duty type: The entries carried IEEPA-specific duties — not Section 301 or Section 232.
- Country of origin: Goods originated from countries targeted by IEEPA tariffs, including China, Canada, and Mexico.
3PL INSIGHT
Refunds go to the importer of record — the entity legally responsible for the shipment at customs clearance. Depending on how entries were structured, that could be the 3PL, the merchant, a freight forwarder, or a customs broker acting on someone’s behalf. Before answering a merchant’s refund question, pull CBP Form 7501 (Entry Summary) and confirm whose name is on it. That single line determines who receives the refund — and who has to file the CAPE Declaration.
How the IEEPA Refund Process Works: CAPE, ACE, and CBP
Refunds are not automatic. CBP has deployed a new tool called CAPE (CBP Automated Payment Engine) inside the existing ACE Portal. CAPE Phase 1 went live April 20, 2026. It accepts two types of entries:
- Unliquidated entries (CBP has not yet finalized duty calculation).
- Entries liquidated within the prior 80 days (the statutory protest window is still open).
Customs brokers can include up to 9,999 entries on a single CAPE Declaration filed on behalf of their importer clients — critical scaling capability for 3PLs filing for multiple merchants.
What to Expect After You File
- Electronic only. Refunds flow exclusively through ACE — no paper checks.
- 60–90 day processing. Valid IEEPA refunds are generally issued within 60–90 days of CAPE Declaration acceptance unless a compliance concern triggers further CBP review.
- Interest included. Refunds are expected to include interest to compensate for the period duties were unlawfully held.
- Staggered rollout. Expect volume bottlenecks. With ~53 million affected entries across ~300,000 importers, phased processing is inevitable.
The One Thing That Will Sink Most IEEPA Refunds
On March 6, CBP issued a warning that deserves attention from every 3PL, customs broker, and ecommerce operator: even after CAPE functionality for IEEPA refunds becomes available, importers will not receive refunds unless they have completed the required setup to receive payments electronically.
| CBP WARNING “Until importers complete the process to receive refunds electronically, the refunds will be rejected.”Of the hundreds of thousands of importers that paid IEEPA duties, only a small percentage have completed this setup so far. |
Since February 6, 2026, CBP has rejected over 12,300 certified refunds because the recipient party did not provide valid U.S. bank account information in the ACE Secure Data Portal. When an ACH setup is missing, CBP cannot deliver the refund — the transfer fails and funds are returned. The importer is typically not notified; they have to go looking.
How to Set Up the ACE Portal for IEEPA Refunds
To prepare for an IEEPA refund, every importer of record needs an active ACE Portal account with electronic payment configured. The ACE Portal is the system of record for:
- Entry summaries and import data
- Compliance notifications from CBP
- Financial reports and statements
- Refund and payment information
Most importantly for this moment, it’s where importers configure the electronic payment (ACH) capability CBP uses to issue refunds. No banking info in ACE, no refund.
Registration and Setup
If a merchant or 3PL entity does not have an ACE Portal account, registration should begin immediately. Guidance and the registration path are available at CBP’s ACE Portal. Existing accounts should be audited to confirm a valid U.S. bank account is on file and that users have the correct roles to act on refund notices.
How 3PLs Should Act This Week: A 5-Step Playbook
This is a moment where operational discipline translates directly into merchant trust. A short checklist for account and customs teams:
- Confirm ACE status for every client (and yourselves). Verify each entity you file for has an active ACE Portal account with valid U.S. bank account information. If not, help them start the process today.
- Pull eligible entries. Generate a list of entries filed between February 4, 2025 and February 24, 2026 that included IEEPA duties. Segment by importer of record so each merchant sees exactly what’s on the table.
- Check entry status and file protests where needed. For entries not yet finalized (liquidated) by CBP, filing a Protest may be required to preserve refund eligibility. Deadlines are short and non-extendable.
- Brief merchants on tax and accounting implications. Refunds will likely count as taxable income, and material expected refunds may trigger financial reporting obligations. Loop in accountants early.
- Set up a monitoring rhythm. Subscribe to CBP’s Cargo Systems Messaging Service (CSMS) and monitor the IEEPA FAQ page. Refund mechanics are still being finalized; updates land weekly.
What Isn’t Changing: Section 301, 232, and 122 Still Apply
It would be a mistake to interpret this ruling as broad tariff relief. The underlying tariff environment remains active:
- Section 122 (10%) has been imposed on most imports as a replacement measure, partially offsetting the removed IEEPA duties.
- Section 301 tariffs on Chinese goods remain in place.
- Section 232 duties on steel, aluminum, and auto parts continue unchanged.
Merchants planning 2026 landed-cost models should treat the IEEPA refund as a one-time recovery, not a baseline shift. The structural cost of importing into the U.S. remains elevated compared to pre-2025 levels.
The 3PL Opportunity Here
Tariff cycles expose which logistics partners operate as vendors and which operate as partners. The merchants who feel taken care of right now — who get a clear email this week explaining their exposure, their eligibility, and their next step — are the ones who don’t shop their 3PL next year.
At ShipMonk, we believe 3PLs win when merchants win. That means treating the IEEPA refund window as a service moment: proactive outreach, clean data, clear language, and a shared checklist. If you handle customs-of-record work for clients, the next 90 days are a chance to prove the partnership in a way a normal quarter simply doesn’t offer.
This situation is evolving quickly. For entry-specific guidance, reach out to your customs broker or trade attorney. For the latest official updates, monitor CBP’s IEEPA FAQ page and subscribe to CBP’s Cargo Systems Messaging Service (CSMS).
