Claiming IEEPA tariff refunds through CBP's CAPE portal

The broker's entry report arrives, and the tariff column is no longer just a cost history. It may be the starting point for a refund. The useful question for a furniture importer is which entries paid IEEPA duties and which of those can enter the refund process.

CBP activated CAPE inside the ACE Portal on April 20, 2026. Start with an entry-level register and your filing broker, then follow the Phase 1 requirements described below. A PO is useful supporting context, but customs entry numbers are the identifiers that drive the filing. CBP launch notice.

General information, not legal advice.

Separate IEEPA from the other import charges

The Supreme Court held on February 20, 2026 that IEEPA does not authorize the President to impose tariffs. The Court's opinion addresses that authority. It does not make every charge on a furniture import an IEEPA duty.

Ask the broker to identify the IEEPA lines in each entry. Keep ordinary duties, Section 232, Section 301, customs fees, and commercial brokerage charges separate. A vendor invoice labeled “tariff surcharge” is not enough to establish the legal basis of the amount customs collected.

Use the Section 232 guide and MPF/HMF guide to keep the categories distinct. The refund register should begin with supported entry data, not a percentage applied to every import invoice from the period.

Establish who can submit the declaration

CBP's April 13 implementation notice limits submission to the importer of record associated with the entries or the broker that filed them. If several brokers handled the store's imports, identify the filing route for each set rather than assuming a newly appointed broker can submit everything.

If the store bought through a distributor and was not importer of record, it cannot claim the distributor's entries as its own. Ask the distributor about the relevant purchases and any commercial credit arrangement. The customs refund and the distributor's obligation to its customer are separate questions.

A lawyer is not required merely to operate the CAPE filing route for an importer. Legal advice may still be needed for disputed entries, preserved rights, or litigation. The brokerage guide helps assign the routine filing work and the records your store needs to retain.

Sort the entries before preparing the upload

Phase 1 covers certain unliquidated entries and certain entries within 80 days of liquidation. That wording matters: not every entry in those broad groups passes all validations. The April notice lists excluded situations, including reconciliation, drawback, specified entry types, open or suspended protests, and certain AD/CVD circumstances.

Ask the broker to assign every entry a status: ready for Phase 1 review, information missing, excluded from Phase 1, or requiring a separate legal or customs decision. For entries more than 80 days past liquidation, obtain advice on the available route rather than repeatedly submitting the same rejected number.

Do not interpret the absence of one general deadline as permission to wait. Entry-specific status and the rolling liquidation window can change the filing position. Check with your attorney where protest, disclosure, or other legal deadlines need protection. A rejected upload is not a substitute for that review.

Build a register that connects customs to the furniture

Request the broker's entry report and supporting summaries. Match each entry to the vendor invoices, POs, and receipt records. A container may cover several POs, and a PO can arrive across several entries, so allow a many-to-many relationship in the working register.

Useful fields include entry number, importer, filing broker, entry date, liquidation status and date, IEEPA amount paid, linked POs, submission reference, acceptance result, refund reference, and reconciliation status. Keep uncertain matches in a review column rather than forcing them into the nearest invoice.

The document hunt is easier while the packing folders still resemble a filing system. Assign one person to maintain the register and a second to review the financial reconciliation. That prevents an accepted entry from being confused with money already received.

Arrange access and ACH refunds before expecting payment

Use the importer's ACE access or the authorized filing broker's account, according to the agreed route. Establish who can see validation results and refund reports. The person submitting the declaration should be able to pass the complete results back to the store's import owner.

CBP requires enrollment for ACH refunds to the importer or designated party. Duty-payment ACH arrangements do not establish refund enrollment by themselves. Confirm the refund setup through the official process with the broker, and keep account details out of ordinary emailed spreadsheets.

The April notice says refunds are electronic and explains the enrollment requirement. Treat access and payment setup as prerequisites, not tasks to discover after acceptance. A processed customs record and a working destination for the funds are different parts of completion.

Submit entry numbers and review every result

CAPE accepts a declaration containing a CSV list of entry numbers; it is not a separate full application for every PO. The April instructions allow up to 9,999 entry numbers in one declaration. Use the template and validation instructions provided in ACE rather than adding invoice details to that upload.

The system validates both the file and individual entries. A file can fail for formatting or submitter reasons. An individual entry can be removed while the remaining entries continue. Retain the accepted declaration number and the rejected-entry reasons, then correct and resubmit only where the route permits.

Do not initiate an IEEPA refund request through a Post Summary Correction; the April guidance prohibits that substitute. Have the broker review any other entry corrections before the CAPE submission. Avoid withdrawing a protest just to clear a validation error without understanding the consequences.

Reconcile consolidated refunds to individual entries

CBP can consolidate refunds by importer or designated party and liquidation date. A bank deposit therefore need not match one declaration or one entry. Use the refund report and entry details to establish what was paid, what remains pending, and any interest or offset.

The April guidance describes a general 60–90-day expectation after acceptance for specified ordinary unliquidated entries, with review and other status exceptions. It also provides for interest under the governing rules. Treat that as processing guidance rather than a guaranteed payment date for every entry in the register.

For a reconciliation example, suppose accepted entries A and B show expected principal of $2,000 and $3,000. A $5,050 deposit should not be posted as a $5,050 reduction of one sofa PO. Establish whether it contains the $5,000 principal plus $50 interest, or a different combination, from the actual refund evidence.

Keep the supporting trail on OrderPilot POs

Record duty as a separate purchasing charge in OrderPilot and retain the entry reference with the supporting PO information. Attach the entry summary and broker breakdown so staff can connect the charge to the goods. Where one entry covers several POs, attach or reference the allocation worksheet consistently. OrderPilot does not submit CAPE declarations; it keeps the purchasing evidence and landed-cost trail that make the refund traceable. When payment arrives, the team can identify the affected receipts and linked customer orders. Use the landed-cost guide before deciding how a confirmed recovery affects the recorded costs.

Decide the accounting and customer treatment after matching the money

Give your CPA the entry reconciliation, original accounting treatment, refund principal, interest, and any costs of obtaining the recovery. Whether and how the receipt affects taxable income depends on that history and the store's accounting circumstances. Do not classify the whole bank deposit from its description alone.

Customer treatment needs the original quote, surcharge wording, and any promises about later reductions. Follow the customer-refund review once the recovery is matched. A customs payment tells the store what it received; it does not by itself settle every customer agreement.

Before the broker call, have the importer entity, entry report, filing-broker list, liquidation dates, ACH-refund status, and missing-document list ready. End the call with a filing owner and a status for every entry. That turns a possible refund into work the store can follow through to reconciliation.

Sources

1. Learning Resources, Inc. v. Trump — Supreme Court of the United States, February 20, 2026.
2. CAPE Phase 1 implementation update, CSMS #68340863 — U.S. Customs and Border Protection, April 13, 2026.
3. CAPE Phase 1 activation, CAMS #68397554 — U.S. Customs and Border Protection, April 20, 2026.