CAPE IEEPA Refunds: Which Entries ACE Still Excludes, Including Finally Liquidated Entries

CAPE IEEPA refunds offer importers and customs brokers a centralized route for recovering eligible duties, but the process does not cover every entry. Finally liquidated entries and several other high-risk categories remain excluded, making accurate inventory segmentation essential before any declaration is uploaded through the ACE Portal.

Understanding Current CAPE Eligibility

Entries That CAPE Can Process

The Consolidated Administration and Processing of Entries system, commonly known as CAPE, is the ACE Portal workflow for submitting IEEPA duty refund declarations. Phase 1 launched on April 20, 2026, and the July 10 operating scope generally covers entries that remain unliquidated or are no more than 80 days past liquidation.

Eligible inventory can include entries with liquidation statuses that are suspended, extended, or under review. These entries generally retain their existing status while CAPE processing occurs. When the refund is validated, payment is typically issued after the entry liquidates or reliquidates and completes the applicable review process.

CAPE can also process reconciliation-flagged Entry Types 01, 02, and 06 when the related Entry Type 09 reconciliation summary has not yet been filed. Certain warehouse withdrawal entries—Types 31, 32, 34, and 38—may also be included. These categories should not be confused with warehouse entry Types 21 and 22, which remain excluded.

What Happens After a Valid Declaration

A CAPE Declaration is filed as a CSV through the CAPE tab in an Importer, Organizational Broker, or Filer sub-account. It cannot be transmitted through the Automated Broker Interface. Each file may contain up to 9,999 entries, so larger portfolios must be divided among multiple declarations using the template available under the Portal’s upload control.

For accepted entries, ACE removes the dutiable IEEPA Chapter 99 tariff numbers and associated duties, creates a new version of the entry summary, and routes the transaction for review. Following validation and the applicable liquidation or reliquidation action, eligible amounts are generally issued as consolidated refunds. Only the importer of record or the customs broker that originally filed the listed entries for that importer may submit the declaration.

Entries ACE Still Excludes From CAPE

Finally Liquidated and Procedurally Restricted Entries

Finally liquidated entries remain outside CAPE’s July 10, 2026 processing scope. Importers should inventory these transactions separately rather than repeatedly submitting them in the expectation that ACE validation will override finality. Until a later CAPE phase is formally activated for applicable finally liquidated entries, the supporting data should be prepared and maintained offline.

Other excluded categories include entries subject to an open protest and entries already associated with a drawback claim. These transactions have separate procedural considerations, and CAPE is not designed to supersede an active protest or drawback process. The trade community also generally cannot use a Post Summary Correction to initiate an IEEPA refund for scenarios excluded from CAPE.

Warehouse Entry Types 21 and 22 are excluded, even though qualifying warehouse withdrawal Types 31, 32, 34, and 38 may be processed. This distinction makes entry-type validation an important control before the refund population is divided into upload files.

Reconciliation, Legacy, and AD/CVD Exclusions

Entry Type 09 reconciliation summaries cannot be submitted through CAPE. In addition, reconciliation-flagged entries become ineligible once the associated Type 09 has been filed. Operations teams should therefore check both the underlying entry flag and the filing status of the reconciliation before classifying an entry as CAPE-ready.

Entries not filed in ACE, as well as transactions without an ACE liquidation status, also remain excluded. Legacy records may require separate research because CAPE relies on ACE entry and liquidation data to identify, update, and process the transaction.

Certain antidumping and countervailing duty entries are excluded when they are pending liquidation under 19 U.S.C. § 1504(d) following Department of Commerce liquidation instructions. Because AD/CVD status can involve instructions, suspension periods, and case-specific liquidation activity, these entries should generally receive specialized review rather than being included in a standard CAPE upload population.

A disciplined exclusion matrix should identify the reason each entry cannot proceed. Useful classifications include final liquidation, open protest, drawback involvement, excluded warehouse type, filed reconciliation, missing ACE status, and pending AD/CVD liquidation. That record provides a defensible audit trail and prevents excluded transactions from repeatedly consuming validation and research resources.

Building a Controlled CAPE Refund Workflow

Segment and Validate Before Upload

A reliable CAPE IEEPA refund process begins with entry-level segmentation. Importers and brokers should first separate clearly eligible entries from excluded or indeterminate records. At minimum, the data set should include entry number, importer of record, filer, entry type, liquidation date and status, reconciliation status, protest status, drawback indicators, AD/CVD indicators, and the relevant IEEPA Chapter 99 lines and duty amounts.

The submitter must then confirm that it is authorized to act. The importer of record may submit its own entries, while a broker may generally submit only entries that the broker filed for that importer. A broker that did not file the original entry should not assume that a general power of attorney alone satisfies CAPE’s submitter requirement.

Each CSV should use the current Portal template and contain no more than 9,999 entries. Large portfolios are typically easier to reconcile when files are divided by importer, eligibility class, liquidation window, or another controlled batch characteristic. Because ABI does not support CAPE Declarations, refund teams should not design the workflow around a conventional ABI correction or transmission queue.

Establish Banking, Reporting, and Reconciliation Controls

ACH refund banking should be enrolled through the ACH Refund Authorization function in the ACE Importer sub-account. This enrollment is separate from the ACH arrangement used to pay duties. Banking should be confirmed before large declarations are submitted to reduce the risk of avoidable refund delays or manual payment handling.

ACE Reports can support both pre-filing validation and post-submission monitoring. ES-003 provides line-level tariff information that can help identify IEEPA indicators. ES-022 supports review of CAPE entry summary activity, while REV-603 provides visibility into trade refund statuses. REV-613 and REV-615 may offer additional refund and financial detail when operational teams need to reconcile payment activity.

Controls should connect the original entry population, submitted CSV, ACE acceptance results, revised entry summary, expected refund, and final payment. Exceptions should be routed by reason rather than placed in a general research queue. This approach allows eligible refunds to advance while finally liquidated, protested, drawback-related, or otherwise excluded entries remain preserved for the appropriate future process.

Frequently Asked Questions

Can Finally Liquidated Entries Be Submitted Through CAPE?

No. Finally liquidated entries remain excluded under CAPE’s July 10, 2026 operating scope. They should be segregated from active declarations and maintained in a separate inventory with supporting entry, duty, liquidation, and claimant data. Repeated uploads will not cause ACE to disregard finality or accept an otherwise excluded entry.

Can a Post Summary Correction Be Used Instead?

Generally, no. A Post Summary Correction is not an alternative method for initiating an IEEPA refund when the entry falls within a category excluded from CAPE. Importers and brokers should evaluate the entry’s procedural status and preserve the necessary documentation rather than using a correction mechanism that does not apply to the refund scenario.

Which Reconciliation Entries Are Eligible?

Reconciliation-flagged Entry Types 01, 02, and 06 may generally be processed when the related Entry Type 09 reconciliation has not been filed. Once the Type 09 is on file, the flagged entries are excluded from CAPE. The Type 09 reconciliation summary itself is also ineligible for inclusion in a CAPE Declaration.

Can Any Customs Broker Submit a Declaration for an Importer?

No. CAPE submissions are limited to the importer of record for the listed entries or the customs broker that filed those entries for that importer. Broker operations should verify the original filer relationship before building the declaration, particularly when an importer uses multiple brokers or has changed service providers.

Does CAPE Support ABI Filing?

No. CAPE Declarations must be uploaded as CSV files through the ACE Portal CAPE tab. ABI cannot transmit the declaration. Files are limited to 9,999 entries, and larger refund populations must be separated into multiple controlled uploads.

How Stable Software Can Help

Automating Refund Inventory and Exception Management

CAPE refund operations require more than generating a CSV. Importers and brokers need reliable entry segmentation, eligibility checks, liquidation tracking, filing-broker validation, batch controls, and refund reconciliation. Stable Software helps trade teams organize these activities in a structured workflow, reducing manual spreadsheet work and preventing excluded entries from contaminating otherwise valid declarations.

Automated exception categories can separate finally liquidated entries, open protests, drawback claims, reconciliation conflicts, warehouse exclusions, and AD/CVD cases while preserving them for later action. Centralized reporting can also connect submitted declarations with revised entry summaries and refund status data. Trade organizations seeking a more scalable approach to IEEPA duty refunds can explore the compliance and customs workflow capabilities available from Stable Software.

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