ACE & CAPE
Refund Guide
Build the entry universe, verify liquidation status, identify CAPE-eligible entries, prepare the refund file, confirm electronic payment information, and track IEEPA refunds through U.S. Customs and Border Protection.
Check the live record before choosing a procedural path.
CAPE functionality, liquidation treatment, court orders, refund procedures, and current tariff measures continue to change. FederalClaims.us maintains those developments on one live-status page so this guide can remain focused on the underlying ACE and CAPE process.
Which entries are yours, and what is their status?
A tariff refund project is not a single claim number. It is an entry-level data problem.
Before deciding whether CAPE, protest, court action, or another pathway applies, identify every affected entry and determine who imported it, what tariff lines were reported, how much duty was paid, and what happened after entry.
ACE provides the government-side operational record. Broker, accounting, banking, invoice, and commercial records should then be reconciled against it.
ACE is the environment. CAPE is the refund process.
Automated Commercial Environment
ACE is CBP's primary trade-processing environment. Importers and authorized trade users use it to access account information, reports, entry data, liquidation information, electronic communications, and other customs records.
- Importer account access
- ACE reports
- Entry information
- Liquidation status
- Declarations
- ACH refund enrollment
- Refund reporting
Consolidated Administration and Processing of Entries
CAPE is CBP's ACE-based process for submitting groups of eligible entries for IEEPA duty refund processing rather than managing each eligible entry as a separate refund request.
- CAPE Declaration
- Entry-number upload
- File validation
- Entry-level validation
- Removal of IEEPA duty treatment
- Liquidation or reliquidation
- Refund processing
Build the file before submitting the declaration.
The objective is not simply to upload entry numbers. It is to create a controlled entry universe that can survive validation failures, refund reconciliation, accounting review, and later legal questions.
Confirm ACE Access
Determine whether the importer has an active ACE Portal account and the appropriate importer-account view.
Confirm Refund Banking
Verify that the appropriate refund recipient has current ACH refund information associated with the relevant importer record.
Build the Entry Universe
Pull affected entries across importer numbers, brokers, ports, tariff lines, and relevant dates.
Classify Entry Status
Identify liquidation, protest, reconciliation, warehouse, drawback, AD/CVD, and other special status.
Prepare CAPE Batches
Separate entries that satisfy current CAPE rules from those requiring another procedural or future processing track.
Validate & Correct
Review file-level and entry-level acceptance or rejection results. Do not treat a validation error as a legal conclusion.
Monitor Liquidation
Track updated entry treatment, liquidation or reliquidation, and the resulting refund process.
Reconcile Payment
Match CBP refund data to banking, accounting, entry-level principal, interest, and downstream allocation.
Make sure the right party can see and act on the record.
ACE access, importer-account association, broker authority, and refund banking are separate administrative questions. Resolve them before a deadline or refund event exposes the gap.
Confirm the importer has active ACE access associated with the relevant importer record.
Identify the person with the administrative authority needed for account and refund settings.
Determine which customs broker filed the affected entries and what authority it has to act for the importer.
Make sure the correct importer-of-record number is associated with the account and underlying entries.
Confirm the appropriate bank information is established before expecting electronic refund payment.
One master dataset for every affected entry.
Build one controlled spreadsheet rather than maintaining separate broker lists, CAPE lists, protest lists, accounting schedules, and litigation lists that cannot later be reconciled.
| Field | Source | Why It Matters |
|---|---|---|
| Entry Number | ACE / entry summary | Primary transaction identifier. |
| Entry Type | ACE / broker export | Can affect current CAPE treatment. |
| Entry Date | Entry summary | Establishes transaction timing. |
| Importer of Record | Entry summary / ACE | Connects the entry to the customs record holder. |
| Broker / Filer | ACE / broker file | Identifies filing and CAPE coordination channel. |
| Port | ACE / entry summary | Supports complete multi-port review. |
| HTS Classification | Line detail | Identifies underlying product classification. |
| Chapter 99 Line | Line detail | Separates IEEPA treatment from other tariff programs. |
| IEEPA Duty | Entry / accounting | Principal refund amount before reconciliation. |
| Liquidation Status | ACE / CBP record | Central to current CAPE and legal pathway analysis. |
| Liquidation Date | ACE / CBP record | Determines the age of the liquidation and procedural posture. |
| CAPE Status | Internal project field | Eligible, submitted, accepted, rejected, pending, or other track. |
| Reconciliation Flag | ACE / broker record | Current CAPE treatment differs depending on Type 09 status. |
| Protest Status | ACE / legal file | Open protest status can affect CAPE submission. |
| Drawback Status | ACE / drawback file | Requires separate status review. |
| AD/CVD Status | ACE / broker / Commerce | Can affect liquidation and CAPE processing. |
| Warehouse Status | ACE / broker file | Different rules apply to warehouse entries and withdrawals. |
| Court Case / Order | Legal file | Relevant for entries subject to court-controlled reliquidation. |
| Refund Principal | CBP / accounting | Reconcile expected and actual refund. |
| Interest | CBP refund record | Separate refund component where applicable. |
| Refund Date | ACE / bank / accounting | Supports payment reconciliation. |
Not every entry belongs on the same declaration.
Unliquidated Entries
Most otherwise eligible unliquidated entries can be evaluated for current CAPE processing.
Recently Liquidated Entries
CBP's current CAPE framework includes many entries submitted within 80 days of liquidation.
Certain Reconciliation-Flagged Entries
Entry Types 01, 02, and 06 flagged for reconciliation can be accepted where the Type 09 reconciliation entry has not yet been filed, subject to current rules.
Qualifying Warehouse Withdrawals
Entry Types 31, 32, 34, and 38 may remain eligible where the IEEPA duties were paid on the warehouse withdrawal.
Open Protest
Entries covered by an open protest are not part of the ordinary current CAPE submission lane described by CBP.
Review Protest Status →Final Liquidation
Entries whose liquidation is final require separate analysis of court orders, current CBP capability, and the importer's litigation status.
Review Court Path →Reconciliation Already Filed
Where the Type 09 reconciliation entry has already been filed, do not assume the underlying entries fall within the same current CAPE lane.
Drawback / AD-CVD / Non-ACE
These categories require specific status review against the current CBP CAPE instructions and underlying liquidation record.
CAPE has been deployed in phases and CBP continues changing validations and special-entry treatment. Confirm the current rules before filing.
Check Current CAPE Status →Submission is a validation process.
A CAPE Declaration should be prepared from the controlled entry universe rather than from an improvised list of entry numbers.
Build the Eligible Batch
Separate entries by importer, procedural status, and current CAPE eligibility.
Prepare the CAPE File
Use CBP's current CAPE template and required file format rather than creating a custom submission format.
Submit Through ACE
The importer or properly authorized filing party submits through the CAPE functionality in ACE.
File Validation
ACE first evaluates whether the declaration itself satisfies current filing requirements.
Entry Validation
Individual entries are then tested against CBP's current eligibility and data validations.
Resolve Rejections
Review the specific error rather than assuming every rejected entry is substantively ineligible.
Track Entry Treatment
Preserve the declaration, validation results, updated entry record, and liquidation or reliquidation history.
Reconcile the Refund
Tie CBP payment back to the declaration, entry universe, principal, interest, ACH deposit, and accounting treatment.
Rejected is not the same as ineligible.
CBP continues to modify CAPE entry validations. A rejected row can reflect formatting, HTS relationships, entry status, data conditions, or a true eligibility restriction.
A validated refund still needs somewhere to go.
CBP has moved refund enrollment into ACE. Refund banking should be treated as part of the recovery file, not an afterthought after the substantive claim is approved.
Identify the Refund Recipient
Confirm the importer or properly designated recipient associated with the refund record.
Check ACE ACH Enrollment
Confirm current banking information through the ACE ACH Refund Authorization functionality.
Review Importer Suffixes
Where importer records use multiple suffixes, confirm the relevant enrollment and account treatment.
Monitor Refund Reporting
Use available ACE refund reporting to identify issued, returned, rejected, or otherwise unresolved refund transactions.
Reconcile the Bank Deposit
Match electronic payment to CBP records, entries, principal, interest, and internal accounting.
Flag the exception before it breaks the batch.
Is Type 09 already filed?
Current CAPE treatment differs between eligible underlying entries flagged for reconciliation and entries where the reconciliation entry has already been filed.
Entry or withdrawal?
Current CBP guidance distinguishes warehouse Entry Types 21 and 22 from qualifying warehouse withdrawals on which the IEEPA duty was paid.
Is there an open protest?
Open protest status can prevent ordinary CAPE submission under the current framework. Do not withdraw or alter a protest without evaluating the legal consequences.
Is liquidation controlled elsewhere?
Antidumping and countervailing-duty proceedings can affect liquidation timing and therefore refund processing.
Is the entry designated on a claim?
Preserve the relationship between the IEEPA entry and any drawback filing before assuming ordinary CAPE treatment.
Is court authority required?
Finally liquidated entries require careful review of the importer's litigation status, current court orders, and available reliquidation mechanism.
Ask for an export, not screenshots.
A customs broker may hold the most complete operational entry file. The objective is to obtain structured data that can be reconciled, filtered, and preserved.
Entry Export
- Entry number
- Entry type
- Importer number
- Port
- Entry date
- Liquidation date
Line-Level Detail
- HTS classification
- Chapter 99 treatment
- Country of origin
- Entered value
- Duty amount
- Other tariff programs
Procedural Status
- Liquidation
- Reconciliation flag
- PSC history
- Protest status
- Drawback status
- AD/CVD status
CAPE Record
- Declarations filed
- Entries submitted
- Validation output
- Rejections
- Corrections / resubmissions
- Processing status
Payment Record
- Periodic statements
- Duty invoices
- Payment proof
- Refund reports
- Interest
- Refund date
Communications
- CBP notices
- Broker correspondence
- Error messages
- Center communications
- Liquidation notices
- Refund follow-up
Reconcile the government record to the business record.
ACE / CBP
What CBP assessed, liquidated, reliquidated, and refunded.
Broker
What the filing system, statements, invoices, and broker records show.
Banking
What was actually paid to or received from the government.
Accounting
How tariff expense, receivables, interest, and refunds were recorded.
Commercial
How tariff cost moved through supplier, customer, and contract relationships.
Add workflow fields to the entry universe.
Manage the CAPE project like a financial audit.
Preserve Original Exports
Keep dated copies of ACE and broker exports before editing or transforming the data.
Use One Master Universe
Avoid competing spreadsheets that create different entry counts and refund totals.
Version the Dataset
Record when entries are added, corrected, rejected, resubmitted, refunded, or moved to another pathway.
Preserve CAPE Results
Save declarations, validation output, error messages, and processing results.
Reconcile to Cash
A project is not complete merely because CBP indicates that an entry was processed.
Keep Legal Status Separate
Do not collapse CAPE, protest, litigation, and commercial allocation into one status field.
ACE & CAPE FAQ
What is the difference between ACE and CAPE?
ACE is CBP's broader trade-processing and account environment. CAPE is the IEEPA refund-processing functionality operating through ACE.
Do I need an ACE account if my customs broker handles my entries?
Broker participation can be important, but the importer should still understand which importer record, entries, refund banking, and account permissions control the project. Do not rely on broker possession of records as a substitute for maintaining the company's own recovery file.
Is every IEEPA entry eligible for CAPE?
No. Eligibility depends on current CBP rules and the status of the particular entry. Liquidation age, protest status, reconciliation, warehouse treatment, drawback, AD/CVD issues, and other conditions can matter.
Can I use a Post Summary Correction to request the IEEPA refund?
Do not treat a PSC as interchangeable with a CAPE Declaration. Use CBP's current IEEPA refund instructions and evaluate any separate entry-correction issue independently.
What if my CAPE entry is rejected?
Preserve the exact validation result, confirm the underlying ACE data and procedural status, check current CBP guidance, and determine whether correction, resubmission, or a separate procedural pathway is appropriate.
What if my entry is more than 80 days past liquidation?
Do not assume ordinary CAPE processing applies. Determine whether liquidation is final, whether a protest exists or remains available, whether the importer is covered by court relief, and what current CBP and court instructions provide.
What if the entry is flagged for reconciliation?
Current CBP functionality can accept certain Entry Types 01, 02, and 06 flagged for reconciliation where the Type 09 reconciliation entry has not yet been filed. Different treatment applies after the reconciliation entry is on file.
Why does ACH enrollment matter?
CBP now uses electronic refund enrollment through ACE. A substantive refund project should therefore verify the designated refund recipient and current bank information as part of the file.
How do I know whether the refund was actually paid?
Reconcile ACE and available CBP refund reporting to the actual bank deposit and accounting ledger. Entry processing, refund authorization, and receipt of funds are distinct events.
Use current CBP instructions.
Once the entry universe is built, choose the pathway.
ACE establishes the transaction record. The next question is whether CAPE, protest, court relief, or another process applies to each entry group.
Find the entry.
Verify the status.
Reconcile the refund.
CBP's CAPE functionality and eligibility rules are being implemented and modified in phases. Entry treatment may depend on importer-of-record status, ACE access, entry type, liquidation status and date, reconciliation, warehouse treatment, drawback, protest activity, antidumping or countervailing-duty proceedings, court orders, and other transaction-specific facts. Verify current CBP instructions and official entry data before filing or altering a protest, reconciliation, correction, or other customs record. This page provides public education and operational information only and does not create an attorney-client relationship or constitute legal, customs, tax, accounting, investment, or financial advice.