What CAPE will and will not handle in early stages
Phase one introduces some important nuances in how entries will be handled. In certain cases, IEEPA duties will be removed and recalculated, but refunds will not be issued right away. Instead, those entries will move through the normal liquidation process, with refunds issued at that point.
Other categories bring additional complexity. Entries tied to antidumping or countervailing duties may remain suspended until the Department of Commerce provides liquidation instructions. Warehouse entries will also continue to follow standard timelines, meaning refunds will not be immediate even after adjustments are made.
At the same time, some entries are excluded from phase one altogether. These include reconciliation entries, drawback claims, entries under active protest and certain AD/CVD cases that are already pending liquidation instructions.
Taken together, these limitations make it clear that CAPE is not yet a universal solution. Importers with more complex entry profiles will need to take a more tailored approach to recovery.
Timing expectations and compliance considerations
CBP has indicated that processing of accepted claims may take up to 45 days, particularly where additional validation or compliance review is required. This reflects a broader reality. Both system rollout and refund execution are expected to follow staged timelines rather than immediate payouts.
That distinction matters. While CAPE is being built to facilitate refunds, it is also designed with stronger validation and review controls. Enforcement remains a priority alongside recovery.
In practice, that means claims need to be accurate, complete and well supported from the start. Data integrity within ACE filings will be closely reviewed, and even small inconsistencies can slow processing or delay payment.
Looking ahead: expanded capabilities, increased complexity
Future phases of CAPE are expected to expand beyond the initial scope and address more complex scenarios. These include entries with final liquidation, reconciliation and drawback claims, complex interest calculations and enhanced compliance and financial controls.
As these capabilities are introduced, access to refunds will broaden. At the same time, the technical and regulatory complexity of the process will increase, requiring more sophisticated coordination across trade, finance and compliance functions.
What this means for importers now
The declaration underscores a critical point. Refund recovery tied to IEEPA tariffs is no longer theoretical. It is operational, but not yet comprehensive.
Organizations should act now, focusing on a few key priorities:
- Identify eligible entries within the current processing scope.
- Validate ACE data and entry classifications.
- Complete electronic refund enrollment requirements.
- Develop a phased recovery strategy aligned to CAPE rollout.
At the same time, timing considerations remain critical. Not all entries will be addressed in the initial phase of CAPE, and certain refund opportunities may depend on actions taken outside of the system.
Importers should evaluate whether filing protests is necessary to preserve potential refund claims, particularly for entries approaching liquidation deadlines or those that may fall outside the initial scope of CAPE processing. Acting sooner rather than later can help preserve flexibility and avoid unintended loss of recovery opportunities as CBP guidance continues to evolve.
A strategic moment for trade leaders
The development of CAPE reflects a broader shift in how trade enforcement and revenue recovery are administered. It combines automation, large-scale data processing and evolving legal requirements into a single operational framework.
For importers, success will depend on more than awareness. It will require coordination across trade compliance, finance and legal teams, along with a clear understanding of where opportunities exist today and where they will emerge next.
As CBP guidance on tariffs continues to evolve alongside CAPE development, organizations that act early and prepare thoroughly will be best positioned to recover value efficiently and avoid unnecessary delays. Baker Tilly continues to monitor these developments and works with clients to translate evolving requirements into practical, actionable strategies.
Ready to evaluate your refund opportunity?
As the refund process moves from legal ruling to administrative execution, the challenge for importers is no longer just eligibility. It is execution. IEEPA tariff refunds will depend on complete and accurate data, defensible methodologies and the ability to navigate evolving CBP requirements. In practice, that means organizing years of entry data, validating duty payments and aligning documentation with how claims will be reviewed. Even where refunds are clearly owed, outcomes will be shaped by how well claims are prepared and submitted.
Baker Tilly’s tariff refund and recovery services are designed to help organizations move from eligibility to execution. This includes assessing refund exposure, identifying eligible entries and building claim packages that can stand up to CBP review.
That work often cuts across multiple functions. Entry-level data needs to be compiled and validated across systems; refund calculations must be consistent, supportable and documentation has to align with how CBP evaluates claims. At the same time, organizations must manage filings and timelines while also considering downstream tax and financial reporting impacts.
This level of coordination reflects a broader reality. Legal entitlement alone does not guarantee recovery. Execution, documentation and timing ultimately determine outcomes.
As CAPE continues to evolve and refund pathways expand, organizations that act early and prepare thoroughly will be better positioned to recover value efficiently and avoid unnecessary delays.
