IEEPA Tariff Refund Recovery Begins

Phase One of CAPE marks a meaningful breakthrough for importers, and PNG Worldwide is prepared to act on behalf of customers to pursue eligible recoveries.

For importers that paid duties under the International Emergency Economic Powers Act, the situation has now materially changed.

This is no longer only a legal or political story. It is now an operational one.

U.S. Customs and Border Protection has announced that on April 20, 2026 it will launch Phase 1 of the Consolidated Administration and Processing of Entries tool, known as CAPE, in the ACE Secure Data Portal. CAPE is the first formal electronic mechanism established by CBP to process eligible IEEPA duty refund claims, including interest, pursuant to court order and applicable statutory authority.

That is the first development that truly matters to importers trying to recover money.

For months, businesses have faced uncertainty around what recovery would look like in practice. There may have been legal arguments, market commentary, and broad expectations, but there was no clear administrative path. That gap is now beginning to close. CBP has moved from concept to mechanism, and that shift is significant. CAPE is designed to consolidate IEEPA refunds rather than process them strictly on an entry-by-entry basis, which gives the trade community a real procedural path forward.

That said, companies should not confuse the launch of a mechanism with automatic recovery.

Phase 1 is important, but it is limited. CBP has made clear that the first phase applies only to certain unliquidated entries and certain liquidated entries that remain within 80 days of liquidation. More complicated scenarios are expected to be addressed in later phases. CBP has specifically indicated that future development may cover areas such as reconciliation-related entries, drawback-linked entries, protested entries, non-ACE entries, some AD/CVD-sensitive situations, and entries where liquidation is already final.

That limitation is not a weakness in the system. It is the reality of a phased rollout. But it does mean that importers need to approach this process with discipline and with experienced support.

The opportunity is real, but it will not manage itself.

CBP has stated that valid IEEPA refunds will generally be issued within 60 to 90 days following acceptance of a CAPE Declaration, unless additional compliance review is required. Refunds will be consolidated by importer of record, or by a properly designated recipient such as a 4811 notify party, and then paid electronically to the bank account associated with the refund setup in ACE.

That should be encouraging to importers, but only if they are actually ready.

CBP has also been explicit that importers and brokers must have an active ACE Portal account and must have refund banking information established correctly in the portal. Refund account information is distinct from payment account information, and refunds are not processed without that setup. CBP’s current refund framework also requires electronic payment through ACH, subject to limited exceptions, following the agency’s January 2026 Electronic Refunds interim final rule.

That means this is not a passive event. It is an execution event.

Importers that believe they paid IEEPA duties should already be identifying the affected entries, reviewing liquidation status, confirming whether those entries fit the Phase 1 framework, validating ACE Portal access, and ensuring ACH refund enrollment is complete and current. CBP’s own guidance urges importers and brokers to begin compiling lists of entries on which IEEPA duties were paid.

This is where the gap opens between companies that recover efficiently and companies that lose momentum.

A portal is not a strategy. A government process is not the same as a managed recovery effort. The importers that succeed here will be the ones that approach the matter with structure, timing discipline, accurate customs data, and a clear understanding of which entries are ripe for action now and which may require additional monitoring as later CAPE phases develop. That is especially true because CBP has confirmed that CAPE Declarations, once filed and accepted, cannot be amended, and additional eligible entries discovered later must be submitted on a new declaration.

That puts a premium on getting the work right the first time.

PNG Worldwide is ready to work on behalf of customers through this recovery process.

We view this development the way serious importers should view it, not as a headline, but as a financial and operational opportunity that must be handled correctly from the outset. The launch of CAPE Phase 1 is the first real step in the recovery of eligible IEEPA tariffs. It establishes a mechanism. It provides a pathway. It creates a credible basis for action. But none of that removes the need for experienced review, coordination, and execution.

That is where PNG Worldwide adds value.

Our role is to bring clarity and control to a process that many importers will find technical, time-sensitive, and commercially significant. We are prepared to support customers in evaluating their entry history, determining where exposure exists, assessing which entries may qualify under the current phase, organizing the documentation and data needed for filing, and helping move the recovery process forward with precision. For businesses that paid substantial IEEPA duties, this should be treated as a working capital recovery initiative, not as a clerical task.

That distinction matters.

The strongest outcomes in customs recovery rarely come from a reactive, fragmented approach. They come from acting early, understanding the rules, and assigning the work to a partner that understands both the customs framework and the business stakes. CAPE is a new tool, but the discipline required around entry review, timing, process control, and refund readiness is not new. That is exactly why importers should not wait for complete certainty on every possible scenario before getting organized. The mechanism is here, the first phase is live, and the companies that move first will be better positioned than the ones that remain on the sidelines.

This is the right moment for measured optimism.

CBP has now done the most important thing the market needed, it has opened the first operational route for recovery. The process is not yet complete, and the agency itself has acknowledged that later phases will be needed to address more complex cases. But the first barrier, the absence of a real mechanism, has now been removed.

For importers, the message is simple.

There is now a path.

There is now a filing structure.

There is now a reason to act.

PNG Worldwide is prepared to represent customers in this process and help them pursue eligible tariff recovery with the level of rigor, urgency, and commercial focus the issue deserves. Companies that believe they may be entitled to IEEPA tariff refunds should begin the review process now, while Phase 1 eligibility, timing, and filing strategy can still be managed deliberately and intelligently.

Call to Action

If your company paid IEEPA-related duties and wants to evaluate recovery options under CBP’s new CAPE process, contact PNG Worldwide to begin a structured review and position your claim correctly from the start.