The CAPE Portal Goes Live April 20. Here's What Every Importer Needs to Do Right Now.

The Court of International Trade has endorsed CBP's tariff refund plan, setting an April 20 launch for the CAPE system — the portal retailers will use to claim back IEEPA duties. Phase 1 covers 63% of eligible entries, and the 45-day processing clock starts when you file.

As we reported throughout March and early April, the legal battle over IEEPA tariffs has been generating more chaos than clarity for retailers waiting on hundreds of millions in potential refunds. That's about to change — at least partially.

Senior Judge Richard Eaton of the U.S. Court of International Trade this week concluded that the government "continues to make satisfactory progress" and that CBP "is on track to meet the April 20, 2026 deadline" for Phase 1 of the refund process, according to Thompson Hine's SmarTrade blog. That endorsement gives importers the clearest timeline they've had since the Supreme Court invalidated the original IEEPA tariff structure.

But the window for action is tight. CBP must file a status report with the court at noon EDT on Tuesday, April 14 — just four days from now. That filing will be discussed in a closed conference before Judge Eaton the same afternoon. Watch for that status update, because it may include Phase 1 launch specifics.

What CAPE Is and How It Works

The Consolidated Administration and Processing of Entries (CAPE) is a new capability being built inside CBP's Automated Commercial Environment (ACE) system, specifically designed to handle IEEPA refund claims at scale. Without a dedicated system, processing the estimated $166 billion in invalidated tariff duties would have been impossible. Forvis Mazars broke down the system's current readiness:

Claim portal: 85% complete
Review and liquidation: 80% complete
Refund processing: 75% complete
Mass processing: 60% complete

Phase 1 will cover approximately 63% of entries for which IEEPA duties were paid or deposited. Once a filer submits the required information, CBP expects to process and liquidate entries within 45 days — unless the entry triggers a compliance review.

Important exclusions from Phase 1: reconciliation entries, drawback claims, entries under active protest, and certain antidumping/countervailing duty cases already pending liquidation instructions. If your entries fall into these categories, you'll be waiting for a later phase.

Who Is Eligible and What to Prepare

Skadden's April 2026 trade insights piece recommends that importers immediately audit their entry filings to identify which ones fall within Phase 1 eligibility. More than 26,000 importers of record have already enrolled in CBP's electronic funds transfer system — a requirement for receiving refunds — representing roughly 78% of impacted entries. If you haven't enrolled, that's the first step.

Supply Chain Dive notes that the 45-day processing window has a critical statutory wrinkle: entries liquidated within 80 days of original liquidation must be reliquidated by day 90 under 19 U.S.C. § 1501. Miss that window and the refund opportunity disappears. Retailers with large import volumes should be working with their customs brokers now to map out which entries hit that deadline.

The Class Action Complication

The refund picture has a shadow hanging over it. As Endcap Brief reported on April 5, retailers who passed tariff costs through to customers now face potential class action exposure. Plaintiffs' attorneys have begun arguing that if the duties were illegal and retailers are receiving refunds, those refunds should flow back to consumers. Morgan Lewis detailed the litigation risk in a March advisory that's now circulating widely among retail legal teams.

The practical effect: some larger retailers are taking a wait-and-see posture on CAPE filings while their legal counsel works out the class action exposure. That's a judgment call, but there's a real cost to waiting — the processing clock only starts when you file, and refunds on billions in duties could fund meaningful working capital relief.

The Bottom Line

April 20 is the date to put on the calendar. Phase 1 of CAPE represents real money — potentially tens or hundreds of millions of dollars for major importers — but only if you file. The time to audit your entry eligibility, confirm EFT enrollment, and engage your customs broker is this week, not next.

Duane Morris summarized the full landscape — including the concurrent Section 301 investigation comment period closing April 15 — in an alert worth reading if your supply chain touches China, Vietnam, or any of the 76 countries under the new USTR investigations.