Customs Compliance
Importers manage the process with US Customs and Border Protection and must review entries, customs documentation, liquidation status, and the Importer of Record’s role.
On April 2, 2025, Donald J. Trump announced a new reciprocal tariff policy on imports into the US. That same day, the White House stated that the President had invoked the International Emergency Economic Powers Act (IEEPA) to declare a national emergency related to the US goods trade deficit and to impose additional duties on imports.
The Supreme Court later ruled that IEEPA does not authorize the President to impose tariffs. That decision opened the door for importers who had paid those duties to claim a refund, provided their transactions met the applicable criteria.
In response, US Customs and Border Protection (CBP), the agency that administers cargo entry into the country and collects import duties, made CAPE available within ACE to channel refund requests. CAPE, short for Consolidated Administration and Processing of Entries, serves as the mechanism for submitting and processing refund claims tied to entries that paid those duties. ACE, short for Automated Commercial Environment, is CBP’s electronic platform for customs declarations, payments, liquidations, and other foreign trade processes.
Key terms in one place
Why CBP Launched CAPE for IEEPA Duty Refunds
CBP launched CAPE to organize the refund procedure in ACE. Rather than processing each request through separate channels, the importer or its authorized customs broker can submit a CAPE Declaration with the entry numbers for which it seeks a refund.
The mechanism centralizes the information in a single electronic channel. The filer uploads a CSV file to the ACE Portal, the system validates the data against the registered entry summaries, and, when ACE accepts the filing, it generates a CAPE claim number for case tracking.
For companies with frequent import operations, this point carries weight, as a single CAPE Declaration can include up to 9,999 entries. This structure supports high-volume claims, provided that the underlying information has been properly consolidated.
Who Can Claim IEEPA Tariff Refunds?
No party in the logistics chain qualifies to file the claim by default. CBP states that the Importer of Record tied to the entries listed in the request, or the authorized customs broker that filed those entry summaries on the importer’s behalf, must submit the CAPE Declaration.
The Importer of Record, or IOR, bears responsibility before CBP for the customs declaration, tariff classification, declared value, regulatory compliance, and payment of applicable duties, fees, and taxes.
Many companies import equipment into the United States without a legal entity of their own, work with various vendors, or route shipments through third parties. In those cases, identifying who served as IOR determines who has authority to file the claim, which records the company needs to gather, and how the team will track the refund.
Which Imports May Qualify?
Eligibility does not depend solely on the payment of IEEPA duties. Companies also need to review the entry type, the customs liquidation stage, and the CAPE program phase that applies to each case.
A company should verify whether its imports carried IEEPA duties, whether ACE processed the entries, where each entry stands in the liquidation cycle, and whether the IOR or the customs broker has the records needed to submit the CAPE Declaration.
IEEPA Duty Refund Checklist
Before moving forward with a claim, companies should review the following items:
Before you file
☐ Confirm whether the company paid IEEPA duties on imports into the United States.
☐ Identify the corresponding entry numbers.
☐ Review the liquidation status of each entry.
☐ Confirm who acted as Importer of Record.
☐ Verify which customs broker filed the original entry summary.
☐ Gather commercial invoices, packing lists, HTS codes, Chapter 99 codes, and proof of payment.
☐ Confirm active access to the ACE Portal.
☐ Set up ACH information to receive refunds.
☐ Prepare the CSV file for the CAPE Declaration.
☐ Review validation errors in ACE.
☐ Track the CAPE claim number.
Not sure which of your entries qualify? Call us: +1 (305) 640-0763
How Aerodoc Manages IEEPA Tariff Refunds for Technology Importers
For many companies, the real challenge lies in gathering the right documentation, validating covered imports, coordinating with the authorized customs broker, and filing the request in ACE without errors.
At Aerodoc, we manage the refund process on the customer’s behalf by reviewing relevant operations, identifying eligible entries, organizing supporting records, and coordinating claim filing with authorized parties.
For companies that import hardware, servers, networking equipment, telecommunications components, satellite technology, or high-value products, this support allows them to delegate a technical and sensitive process to a partner specializing in IOR, customs compliance, and international logistics.
Did your company pay IEEPA duties that may now be recoverable?
Aerodoc reviews your operations, identifies eligible entries, organizes records, and coordinates the CAPE claim with authorized parties.
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