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On Monday, April 20, U.S. Customs and Border Protection (CBP) launched its simplified refund process (CAPE), arising from developments related to the so-called “tariff surge” implemented during the administration of Donald Trump. In light of this, our partner Bruno Corrêa Burini prepared content in a question-and-answer format on the subject.

Understand who may submit a refund request, which entries must be submitted, what data must be provided in the declaration, and other details by accessing the images.

Who may submit a refund request (CAPE Declaration)?
The importer of record or the customs broker who originally filed the entry.

Which entries may I submit?
Importers may, in general, submit CAPE Declarations for:
• Entries that have not yet been liquidated
• Entries that were liquidated up to 80 days prior to the submission of the CAPE Declaration (for example, since January 30, 2026, if the declaration is submitted on April 20)

CAPE will not accept declarations for:
• Entries flagged for reconciliation, as well as Entry Type 09 – Reconciliation Summary
• Entries included in drawback claims
• Entries covered by an open protest
• Entries not recorded in ACE or without liquidation status in the system
• Entries subject to antidumping or countervailing duties (AD/CVD) still pending liquidation in accordance with instructions from the Department of Commerce

What about other entries?
CBP expects to release future CAPE updates to cover entries not included in Phase 1. However, there is currently no timeline for this.

In the meantime, we recommend filing protests as close as possible to the 180-day deadline following liquidation (generally within the last 30 days). This helps preserve the company’s legal rights while CBP implements new CAPE functionalities.

What data must be submitted in the CAPE Declaration?
CAPE will require only the submission of a .CSV file containing the list of entry numbers for which a refund is requested. Each file may contain up to 9,999 entries, and more than one CAPE Declaration may be submitted.

Notes:
• The list of entries must be free of duplicates prior to submission of the .CSV file
• The file must be separated by importer of record (if more than one) or by customs broker (if there are multiple parties responsible for the entries)

How will refunds be processed?
Electronically, via ACH. To receive the refund, banking information must be registered with CBP.

When will refunds be processed?
CBP estimates that refunds will generally be processed within 60 to 90 days after submission of the CAPE Declaration. If any entry is selected for additional review, the timeframe may be longer.

New information regarding IEEPA tariff refunds will be updated on the CBP website as it becomes available.

Useful links:
How to apply for an importer account in the customs system (ACE)

CBP CAPE Declaration Quick Reference Guide

How to register for electronic refunds

Information on IEEPA tariff refunds

Click here to also access our previous content on impacts and possibilities for Brazilian companies.