IEEPA Duty Refund Services
The Supreme Court ruled IEEPA tariffs unlawful. CBP launched the CAPE system to process refunds. But refunds are not automatic — importers or their brokers must identify eligible entries, prepare a validated list of affected entries in .CSV format, and submit a CAPE Declaration through the ACE Portal. That means someone needs to pull the data, sort through liquidation statuses, flag exclusions, and identify the list of eligible entries. Most importers don’t have the bandwidth or ACE expertise to do this efficiently. That’s where we come in.
ACE Data Pull & Rollup
We extract your entry data from the ACE Portal and consolidate it into a clear summary — entry numbers, liquidation dates, liquidation status, IEEPA HTS lines, and duty amounts — organized by Importer of Record (IOR) as required by CAPE
Entry Classification
Every entry is categorized into one of three buckets:
- Phase 1 Eligible — Allowable unliquidated entries and entries liquidated within 80 days, ready for CAPE now
- Future Phase — Entries excluded from Phase 1 (reconciliation, drawback, open protest, AD/CVD pending, final liquidation) that CBP is addressing in later phases
- Requires Action — Entries approaching protest deadlines or with compliance considerations that need attention before filing
Dollar Amount Analysis
We calculate your estimated refund exposure across all categories — what you can recover now in Phase 1, what’s expected in future phases, and total IEEPA duties paid. No guesswork.
CAPE-Ready Entry List
We identify the list of entries for the final CSV file formatted to CBP’s CAPE Declaration specifications — validated entry numbers, de-duplicated, filtered for Phase 1 eligibility — ready for upload to the ACE Portal.
Broker & Counsel Coordination
We work directly with the Importer and your customs broker or trade counsel to ensure the data is accurate, the filing strategy is sound, and everyone is aligned before the CAPE Declaration is submitted.
Whether you’re just getting started with ACE or need to refine your skills, we can help. Training covers everything from submitting an ACE application to pulling detailed reports. Need help setting up a report? Modifying one? Scheduling automated reports? No problem. More importantly, we’ll show you how to leverage ACE data to uncover potential compliance risks and optimize your importing process.
Important Disclaimers & Disclosures
Not Legal Advice
Deleon Trade LLC provides trade compliance consulting and data analysis services. Nothing on this website or in our deliverables constitutes legal advice. We are not a law firm, and our services do not create an attorney-client relationship. For legal guidance regarding IEEPA refunds, protests, or Court of International Trade proceedings, consult a licensed trade attorney.
No Protest Filing for Entries Beyond 80 Days Post-Liquidation
Our services do not include filing protests with CBP. For entries that are more than 80 days past their liquidation date, CBP has not yet provided instructions for processing refunds through CAPE. These entries are expected to be addressed in subsequent phases of CAPE, but the timeline and mechanism have not been confirmed. We will identify and flag these entries in your analysis, but we cannot file protests or guarantee a refund pathway for them at this time.
Refund Amounts Are Estimates
All dollar amounts provided in our analysis are estimates based on ACE data available at the time of extraction. Actual refund amounts are determined solely by CBP during the liquidation or reliquidation process and may differ due to offsets, compliance holds, AD/CVD adjustments, or other factors. We do not guarantee any specific refund amount or timeline.
CBP Processing & Government Appeal Risk
IEEPA duty refunds are being processed under court order (Euro-Notions Florida, Inc. v. U.S. Customs and Border Protection, et al., Court No. 25-00595, U.S. Court of International Trade). The government retains the right to appeal, which could delay or alter the refund process. CBP has stated that CAPE refunds are expected within 60–90 days of an accepted Declaration, absent compliance review, but this is not guaranteed. Deleon Trade LLC has no control over CBP processing timelines, system functionality, or government legal decisions.
Evolving CBP Guidance
CBP’s CAPE system, validation rules, and refund procedures are subject to change. The information on this page reflects guidance available as of April 13, 2026. We make reasonable efforts to stay current, but CBP may update its requirements, expand or modify phase scope, or issue new instructions at any time. Clients are encouraged to verify current requirements with CBP or their trade counsel before filing.
Data Accuracy & ACE Access
Our analysis is only as accurate as the data available in ACE at the time of extraction. Entries not filed in ACE, entries without liquidation status in ACE, or entries with incomplete data may not be captured in our analysis. It is the client’s responsibility to ensure that ACE Portal access is current and that ACH refund enrollment is completed prior to any CAPE Declaration submission.
Why Choose a Third-Party Trade Consultant?
Expertise: Access to a wealth of knowledge and experience.
Efficiency: Streamline operations and reduce compliance risks.
Objectivity: Unbiased assessments for sustainable improvement.
Ready to Enhance Your Compliance?
Let's Start the Journey Together
Contact us today to discover how our tailored solutions and expert guidance can propel your business towards compliance excellence.