CAPE Phase 1 Checklist for Small Importers

Updated May 5, 2026. CAPE Phase 1 is live, but it is still not a magic refund button. Small importers need the right ACE access, current ACH refund enrollment, entry-level records, broker coordination, and a clean accounting file before they can make useful decisions about an IEEPA tariff refund.

CBP is deploying the Consolidated Administration and Processing of Entries, or CAPE, in phases through the ACE Secure Data Portal. Phase 1 covers certain unliquidated entries and entries liquidated within the preceding 80 days. CBP says valid IEEPA refunds will generally arrive within 60 to 90 days after acceptance of a CAPE Declaration, unless compliance review, liquidation status, warehouse status, offsets, or other issues slow the process.

This checklist is written for small importers that do not have a full trade compliance department. It is not legal advice, customs brokerage advice, or a substitute for a licensed broker or trade counsel. DeMar Consulting Group helps businesses organize the finance, accounting, and cash-flow side so the filing conversation is better supported.

What Changed in May 2026

On April 20, 2026, CBP made CAPE available in ACE for Phase 1 IEEPA duty refund requests. The process uses a CAPE Declaration, which is a CSV list of entry summary numbers. CBP says the file does not require other information in the upload, and each declaration can include up to 9,999 entries.

That sounds simple until a business starts building the list. The filer still has to answer five questions: which entries are eligible, who has authority to file, whether the entries fit Phase 1, whether each entry includes an IEEPA Chapter 99 line, and whether the refund payment path is ready. A spreadsheet with the wrong entries can create rejections, delays, or inflated expectations.

Small importers should also remember that CAPE focuses on IEEPA duty refunds. It does not turn every tariff-related charge into recoverable cash. Separate IEEPA duties from Section 232, Section 301, ordinary customs duties, freight, broker fees, and other import costs. Then read our guide to which tariffs are not refundable before treating a gross landed-cost number as a refund estimate.

Refund Readiness Is Different From Filing a CAPE Declaration

CBP is clear that only the importer of record or the licensed customs broker who filed the entries can file a CAPE Declaration. That matters for small companies that import through brokers, freight forwarders, marketplaces, distributors, or related entities. The company that paid the economic cost may not be the party listed as importer of record on every entry.

Before a business asks anyone to file, someone should own the readiness file. That person does not need to become a customs lawyer. They do need to gather entry data, confirm who filed each entry, map duty payments to accounting records, and keep management from making cash decisions based on entries that have not been accepted.

In plain terms, the customs advisor answers filing and eligibility questions. The finance team answers cash-flow, accounting, tax, and documentation questions. The best refund projects keep those lanes connected without blurring them.

A Small Importer CAPE Phase 1 Checklist

Start with access. The importer of record and any authorized broker involved in the process should have the right ACE Portal access. If your company has not used ACE much, test access early. The filing list should not be ready before the team learns that the right person cannot log in, the importer sub-account is missing, or no one knows who owns the account.

• Confirm the importer of record for each entry under review.
• Confirm which licensed customs broker filed each entry.
• Verify ACE Portal access for the importer sub-account.
• Confirm ACH refund enrollment and current bank information.
• Pull entry summaries and identify IEEPA Chapter 99 duty lines.
• Separate unliquidated entries from liquidated entries.
• Flag entries liquidated more than 80 days ago.
• Flag entries tied to reconciliation, drawback, open protests, warehouse status, AD/CVD review, or other special handling.
• Export a baseline file before anyone submits a declaration.

That list is not glamorous, but it protects the refund estimate. It also gives the owner, bookkeeper, broker, and CPA one shared set of facts instead of several partial spreadsheets.

Why the 80-Day Window Matters

During Phase 1, ACE will accept CAPE Declarations for entries liquidated within the preceding 80 days. CBP says this gives enough time to process and reliquidate entries by the 90th day under the voluntary reliquidation window. Entries outside that window may belong in later CAPE phases, a different administrative process, or a legal strategy. That is a broker or trade counsel conversation, not a guess for the accounting team.

For management reporting, keep the entry list split by status. Put clean unliquidated entries in one bucket. Put finally liquidated entries, reconciliation entries, and entries with missing IEEPA HTS lines in separate buckets. Those categories may all be important, but they do not have the same timing or confidence level.

If your company is already planning around refund cash, this is where the forecast can go wrong. The gross amount of IEEPA duties identified is not the same as the Phase 1 filing amount. The filing amount is not the same as the accepted amount. The accepted amount is not the same as spendable cash if there are offsets, rejected entries, or delayed liquidation.

What to Hand to Your Broker or Trade Advisor

A broker can move faster with a clean packet than with a messy export. Gather the entry summary numbers, importer of record, broker of record, entry date, liquidation status, liquidation date if applicable, IEEPA HTS line, and IEEPA duty amount. Add any known exception such as reconciliation, drawback, protest, warehouse, or AD/CVD status.

Also include finance questions that need coordination. Where were the original duties recorded? Did the business pass tariff costs through to customers? Are any refunds expected to be paid to a Form 4811 notify party? Is there outstanding CBP debt that could offset the refund? Who inside the company should receive status updates?

That handoff keeps the broker focused on the filing mechanics while finance keeps the business from losing track of cash, accounting, and tax implications.

Where the Refund Can Affect the Books

A tariff refund does not become clean accounting because cash eventually lands in the bank. Tie the refund back to the original duty treatment. Some businesses recorded duties in inventory. Others posted them to cost of goods sold, freight, customs duties, taxes and licenses, or a miscellaneous expense account. Some passed part of the cost through to customers.

Before recording a receivable or income item, build a support file that connects the refund entry to the original cost. If the inventory is still on hand, the accounting question may differ from a case where the product was already sold. If the business deducted the duty in a prior period, the tax advisor may need to review timing. If the refund includes interest or an offset, the bank deposit may need more than one accounting line.

For a deeper accounting walkthrough, see how to account for a tariff refund in your books. If cash timing is the bigger issue, pair this checklist with our guide to tariff refunds and cash-flow planning.

Sources

• CBP: International Emergency Economic Powers Act (IEEPA) Duty Refunds
• CBP: ACH Refund Enrollment
• Supreme Court: Learning Resources, Inc. v. Trump