The Executive Director of the United States (US) Customs and Border Protection (CBP) Trade Programs Directorate, Brandon Lord, provided an update to the US Court of International Claims (CIT) on 12 March 2026, describing how CBP is building a new, dedicated process within the Automated Commercial Environment (ACE) to administer valid refunds of additional ad valorem duties imposed under the International Emergency Economic Powers Act (IEEPA). CBP filed this update in response to a 4 March 2026 order from the CIT in Atmus Filtration, Inc. v. United States.

The Consolidated Administration and Processing of Entries (CAPE) Claim Portal is designed to intake importer claims, remove IEEPA-specific Chapter 99 Harmonized Tariff Schedule (HTS) provisions from entry summaries, recalculate duties and interest and route consolidated electronic refunds, while allowing CBP review and standard liquidation/reliquidation controls.

For more on the CIT's original order requiring CBP to establish a process to liquidate and reliquidate entries, see EY Global Tax Alert, US Court of International Trade orders CBP to liquidate and reliquidate entries without IEEPA duties, dated 5 March 2026.

In a subsequent order issued on 12 March 2026, the CIT reported that development of the claims portal was progressing at a "satisfactory" pace. The CIT directed CBP to continue advancing the project and required that a further update on the status of the portal be submitted on 19 March 2026. This indicates the court's ongoing oversight and expectation of steady progress toward implementation.

CAPE component overview and development status

1. Claim Portal (≈70% complete): The Claim Portal is a web-based tab in importer and broker ACE Portal accounts (not Automated Broker Interface) where filers submit a "CAPE Declaration" listing entry summaries via Comma-Separated Values (CSV) upload.
• File validations will confirm required data, formatting, importer-of-record or authorized broker status and file integrity; submissions failing file validations will be rejected with error messages for correction and resubmission.
• Entry-level validations will verify that each entry exists in ACE and has at least one IEEPA Chapter 99 HTS number; entries failing entry-level validations will be removed from the declaration, with the remainder continuing through processing and the option to resubmit corrected entries on a separate declaration.
2. Mass Processing (≈40% complete): Mass processing automatically removes IEEPA HTS numbers from validated entries and runs standard ACE duty calculation checks; it recalculates duties as if IEEPA duties were never declared. Declarations that pass these validations are accepted for further processing.
3. Review and Liquidation/Reliquidation (≈80% complete): This review automatically schedules liquidation or reliquidation a set number of days after declaration acceptance to permit CBP review, updates entry summaries to reflect revised total duties and automatically calculates interest. Liquidation/reliquidation processing will occur Monday through Thursday each week.
4. Refund (≈60% complete): The refund process directs completed entries to a CAPE-specific workflow in the ACE Collections refunds module. Refunds (with interest) will be consolidated by liquidation/reliquidation date and by importer of record (or a CBP Form 4811 designee) and issued electronically to the designated bank account.

Phased development and scope

CBP anticipates deploying CAPE in phases, beginning with the core functionality above and adding capability for more complex scenarios over time. In its first phase, CAPE is expected to process most formal and informal entries on which IEEPA duties were paid. Certain categories will be excluded, however, including: unliquidated entries subject to antidumping or countervailing duties; entries with liquidation status "Suspended," "Extended" or "Under Review" in ACE; and some entry types (e.g., warehouse withdrawals and entries designated on a drawback claim). CBP will issue detailed guidance describing the scope and functionality of each phase as it is implemented.

What this means for businesses

CAPE will centralize IEEPA duty refunds within ACE and will aim to reduce manual processing by automating validations, recalculations, liquidation or reliquidation scheduling and refund consolidation. Filers will submit claims through a new ACE Portal tab using CSV uploads of entry summaries, and each submission will undergo file-level and entry-level validations before processing.

Because the early phases will not accommodate all entry types or statuses, importers should identify entries most likely to qualify in the initial phase and prepare for later phases that will handle more complex situations. Once processed, refunds will be consolidated by liquidation date and disbursed electronically to the importer of record or a Form 4811 designee.

Actions to consider

Actions for businesses to consider, depending on their specific situations, include:

• Confirm ACE Portal access for importer and broker users and designate internal owners to prepare and upload CSV files listing IEEPA-affected entry summaries.
• Compile entry summary numbers and confirm that affected entries include the relevant IEEPA Chapter 99 HTS numbers in ACE; where possible, reconcile duty components so IEEPA amounts can be isolated if queried.
• Segment entries by status to identify those likely processable in phase one versus entries expected to be handled in later phases (e.g., antidumping/ countervailing duty (AD/CVD) suspended entries as well as those marked "Suspended," "Extended" or "Under Review").
• Verify or establish electronic refund arrangements and any CBP Form 4811 designations to ensure consolidated payments route to the intended account.¹
• Watch for CBP communications on CAPE launch timing, detailed filing instructions and phase scope; align broker instructions and internal controls accordingly.
• Monitor the court-ordered update on 19 March 2026 and any final CIT determinations.