When the CBP CAPE system launches (targeted for late April 2026), importers will file IEEPA refund claims by uploading a CSV (Comma-Separated Values) file containing a list of entry summaries. If your entry data is scattered across multiple systems, spreadsheets, and customs broker records, you will waste valuable time organizing it when you should be filing your claim.
The time to organize your data is now. Here is how to do it.
Step 1: Gather All Your Entry Records
Start by collecting all of your CBP Form 7501 (Entry Summary) records for the IEEPA period. The IEEPA period is generally February 2018 through February 2026, but the exact dates depend on the specific tariff actions that applied to your imports.
Where to Find Your Entry Records:
- Your Customs Broker: If you used a customs broker to handle your imports, they have copies of all entries they filed on your behalf. Request a complete list of entries for the IEEPA period.
- ACE (Automated Commercial Environment): If you are an importer of record with direct ACE access, you can download your entry history directly from ACE. Log in to ACE and use the "Entry Search" function to retrieve all entries for the relevant period.
- CBP Ports: If you cannot locate entries through your broker or ACE, you can request them from the CBP port where the entries were filed. This process is slower but is an option of last resort.
Step 2: Create a Master Spreadsheet
Create a spreadsheet (Excel, Google Sheets, or similar) with the following columns:
- Entry Number: The CBP entry number (format: port code + entry number, e.g., 0000-12345678)
- Entry Date: The date the entry was filed
- Country of Origin: The country from which the goods were imported
- HTS Code: The Harmonized Tariff Schedule code for the primary product
- Product Description: A brief description of what was imported
- Dutiable Value: The value on which duties were calculated
- Total Duties Paid: The total amount of duties paid on the entry
- IEEPA Duties Paid: The portion of duties that were IEEPA-based (this may require research)
- Liquidation Date: The date the entry was liquidated by CBP
- Status: Whether the entry is liquidated, under protest, or has other special status
Step 3: Identify IEEPA-Subject Entries
Not every entry will be subject to IEEPA tariffs. You need to identify which entries were assessed IEEPA duties.
IEEPA Entries by Country of Origin:
- China: Most entries from China between February 2018 and February 2026 were subject to IEEPA tariffs (with limited exceptions). Check the HTS code against the USITC's published lists of IEEPA-affected codes.
- Canada and Mexico: Most entries from Canada and Mexico between June 2018 and February 2026 were subject to 25% IEEPA tariffs under Section 232 authority.
- Other countries: Entries from Vietnam, India, Bangladesh, the EU, and South Korea may have been subject to IEEPA tariffs on specific steel and aluminum products. Check the HTS code against the published tariff lists.
The USITC website maintains detailed lists of HTS codes affected by each tariff action. Cross-reference your entries against these lists to identify which entries were IEEPA-subject.
Step 4: Calculate IEEPA Duty Exposure
For each IEEPA-subject entry, calculate the IEEPA duties paid:
Formula: Dutiable Value × IEEPA Tariff Rate = IEEPA Duties Paid
Example: An importer imported $100,000 worth of goods from China on which a 25% IEEPA tariff was assessed. The IEEPA duties paid = $100,000 × 0.25 = $25,000.
If an entry was subject to multiple tariff actions (e.g., a base tariff plus an IEEPA tariff), you need to isolate only the IEEPA portion. This is where working with a customs broker or IEEPA specialist is valuable — they can help you separate IEEPA duties from other duties.
Step 5: Verify Your Data
Before you finalize your spreadsheet, verify your data:
- Spot-check entries: Select a few entries at random and verify them against your original CBP Form 7501 or your customs broker's records.
- Cross-check totals: Sum your total IEEPA duties paid and compare it to any estimates or preliminary calculations you have made.
- Verify entry numbers: Ensure entry numbers are correctly formatted and match CBP records.
Step 6: Prepare for CSV Upload
When the CAPE system launches, you will upload your entry data via CSV file. Prepare your data now in a format that will be easy to convert to CSV:
- Ensure all data is in a single, clean spreadsheet
- Remove any formatting (colors, fonts, merged cells) that might cause issues in CSV conversion
- Verify that all required fields are populated
- Save a backup copy of your spreadsheet
Step 7: Enroll in ACH Electronic Refunds
Before you file your IEEPA refund claim, ensure that your company is enrolled in CBP's ACH (Automated Clearing House) Electronic Refund program. This is the system through which CBP will process refunds.
If you are not enrolled, contact your customs broker or CBP directly to complete the enrollment process. This can take 2–4 weeks, so do not wait until the last minute.
The Bottom Line
Organizing your entry data now will save you weeks of work when the CAPE system launches. Start by gathering your records, creating a master spreadsheet, identifying IEEPA-subject entries, and calculating your exposure. By the time the system is operational, you will be ready to file your claim immediately.
Conglobus International can help you organize your entry data and prepare your refund claim. Contact us for a free assessment of your exposure.