Beginning April 20, 2026, U.S. Customs and Border Protection (CBP) will launch the first phase of the CAPE (Consolidation, Administration, and Entry Processing) tool to facilitate the refund of duties paid under the International Emergency Economic Powers Act (IEEPA).

Here is a simplified guide on who can claim and the steps required to do so:

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1. Who can apply for reimbursement?

The Importer of Record (IOR) who made the entry of the goods into the U.S. or the authorized broker who filed the entries on behalf of that importer is entitled to claim reimbursement.

• If you are a Spanish company that exported: Normally, the refund will be received by your U.S. customer (if he was the importer) or by your U.S. subsidiary if it acted as importer.
• If you are a company with a U.S. subsidiary: Your subsidiary, as IOR, is the entity that must manage the process.

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2. Cases in which a claim can be filed (Phase 1)

In this first phase, only certain types of entries (import operations) are eligible:

• Unsettled entries: Those that are still pending administrative closure by customs.
• Recently settled entries: Those whose settlement date does not exceed 80 days.
• Special statuses: Entries with suspended, extended or under review settlement status, as well as warehouse entries. In these cases, the refund will be validated, but will be issued at the time of final settlement.

What is left out of this stage? Entries subject to antidumping or countervailing duties (AD/CVD), those with open protests, drawback claims (when those products or their components are exported later) or those whose liquidation is already final (more than 80 days) will not be accepted in this first stage.

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3. Essential requirements for the company

In order to receive the money, two technical requirements must be met in the U.S. system:

• ACE Portal Account: The importing company must have an active account in the Automated Commercial Environment (ACE) portal, specifically with the sub-account view of “Importer”.
• ACH Refund Authorization: All refunds will be paid electronically via Automated Clearing House (ACH). It is necessary to register a U.S. bank account in the “ACH Refund Authorization” tab of the ACE portal.

Note for Spanish companies: If the subsidiary does not maintain a U.S. bank account, you may designate your broker as a “notify party” on Form 4811 so that the broker can receive the refund on your behalf.

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4. Procedure to follow

Once the system is enabled on April 20, the steps are:

• Prepare the entry list: Collect the 11-digit entry numbers (unique identifiers for each import transaction with U.S. Customs) on which IEEPA duties were paid.
• Upload the “CAPE Statement”: A CSV file must be uploaded through the new “CAPE” tab in the ACE Portal. Each file can contain up to 9,999 entry numbers, but multiple statements can be uploaded if necessary.
• Validation: The ACE system will perform automatic validations to verify that the entry numbers exist and that the applicant is the IOR or authorized broker.
• Receipt of payment: Once the declaration is accepted, CBP estimates that refunds (including interest) will generally be issued within 60 to 90 days.

It is essential that companies do not attempt to request these refunds through a Post Summary Correction (PSC), as CBP has expressly prohibited this method for IEEPA tariffs, forcing the exclusive use of the CAPE tool.