IEEPA Duty Refund Guide for Importers

Quick Summary

To request an IEEPA refund, the importer generally needs to:

  1. Confirm the company has a CBP Form 5106 importer record.
  2. Open or access an ACE Portal Top Account.
  3. Confirm the ACE account has an Importer sub-account.
  4. Add ACH refund bank information in ACE.
  5. Identify eligible entries.
  6. Upload a CAPE Declaration CSV file through ACE.
  7. Monitor refund status in ACE reports.

Step 1: Confirm You Are the Importer of Record

The refund should generally be filed by:

  • The Importer of Record, Customs Broker, freight agent, or any third party with a power of attorney.

Before starting, gather:

  • Legal company name
  • EIN or importer number
  • CBP Form 5106 information (here or ask your customs broker to update)
  • ACE Portal login email, if already created
  • Entry numbers
  • Entry dates
  • Liquidation dates
  • Amount of IEEPA duties paid
  • Broker/filer information
  • U.S. bank account information for ACH refunds

Important: the entry filing date is not the same as the liquidation date. CAPE eligibility depends heavily on liquidation status and liquidation date.

Step 2: Check If You Already Have an ACE Portal Top Account

Go to the CBP ACE Portal login page.

Use link: CBP ACE Portal Login

Try logging in with the company’s ACE user email.

If you can log in, check whether you can see:

  • Top Account
  • Importer sub-account
  • ACH Refund Authorization tab
  • CAPE tab

If you already have the Top Account and Importer sub-account, skip to Step 5.

If you can log in but do not see the Importer sub-account, go to Step 4.

If you cannot log in or do not have an ACE account, go to Step 3.

Step 3: Open an ACE Portal Top Account

If your company does not have an ACE Portal Top Account, use CBP’s importer account application.

Use link: CBP Automated ACE Portal Top Account Application for Importers

CBP’s importer application is used to request:

  • An ACE Portal Top Account
  • A Trade Account Owner, also called TAO
  • Access to the company’s Importer sub-account connected to the company’s CBP Form 5106 importer record. Form 5106 use link: Form 5106

You will need the company’s existing importer record information. If the company does not have a CBP Form 5106 importer record on file, contact your customs broker or email form 5106 directly to :CBP first to create or update the importer record.

When filling out the ACE account application:

  • Use the company’s legal name.
  • Use the company’s EIN/importer number.
  • Use the company owner or authorized employee as the contact/user.
  • Do not use a freight forwarder, broker, or consultant email as the owner unless they are officially authorized to manage the company’s ACE account.
  • If the form asks for organization name and gives an error that the value is too long, shorten the company name using common abbreviations such as Inc., Corp., LLC, Intl, or Co.

    1. Here is the site to open a top account: https://ace-accounts.cbp.gov/s/importer-form. Please fill in            the highlighted areas.


    2. A validation code is emailed to the address on file with the importers form 5106. The code is valid           for only 10 minutes.

    3. With successful validation, you will see more fields to fill out. Please fill out the highlighted fields.          Acknowledge terms and submit application. 

 

If you receive an error such as “Account and User Already Exist,” “Login User Email Not Found,” or you believe the importer record is already tied to another ACE account, contact ACE support.

Email: ACE.Support@cbp.dhs.gov


Step 4: Confirm the Importer Sub-Account Exists

After the ACE Top Account is active, check whether the account has an Importer sub-account. Click here to make a Ace Portal account. Please note, this is separate from ace TOP account. You are creating a different account. One is a Ace Top Account in Step 3 and next is a Ace Portal account in step 4. Once you create your account, you will be asked for another validation code sent to your email. Fill in the code, log in and click on "ACE"

After making the Ace Portal account:

In ACE, go to:

Accounts → Top Account → Account Types / Sub-Accounts / Importer View

You need the Importer sub-account because the ACH refund setup and CAPE filing are tied to the importer sub-account view.

If you do not see the Importer sub-account:

  1. Confirm you are logged in as the Trade Account Owner or Proxy Account Owner.
  2. Check whether the company’s CBP Form 5106 importer record exists.
  3. Try adding the Importer account type or Importer identifier under the Top Account.
  4. If ACE does not allow it, contact ACE Support.

Email: ACE.Support@cbp.dhs.gov or IEEPArefunds@cbp.dhs.gov

When contacting support, include:

  • Company legal name
  • EIN/importer number
  • ACE username/email
  • Screenshot of the issue
  • Error message, if any
  • Statement that you need the Importer sub-account added to the ACE Top Account for ACH refund and CAPE access

Sample email:

Subject: Request to Add Importer Sub-Account to ACE Top Account

Hello ACE Support,

We are requesting assistance adding our Importer sub-account to our ACE Portal Top Account so that we can complete ACH Refund Authorization and submit CAPE declarations for IEEPA duty refunds.

Company legal name:
EIN / Importer number:
ACE username / login email:
Trade Account Owner name:
Issue:

Please let us know what additional information is required.

Thank you.

Step 5: Add ACH Refund Bank Information

After your ACE importer Sub-Account is active. Fill in the ACH information under the importer Sub- Account. CBP refunds are issued electronically by ACH. If ACH refund information is missing or incomplete, the refund may be delayed or rejected. 

In ACE:

  1. Log into the ACE Portal. Then click on ACE.
  2. Open the Importer sub-account view.
      3. Click on importer account under your company name.


      4.Find the ACH Refund Authorization tab.

    4. Click "add ACH info"

    5. Enter your bank details, routing number and account number. Then click "submit"

    6. To check your details, refresh the screen, navigate back, and click "get info/refresh" to see the bank         details or click update to edit them. 
    7. Your ACH is now complete.


Step 6: Special Situation: Foreign Importer Without a U.S. Bank Account

If the importer does not have a U.S. bank account, the importer may need to designate another eligible party to receive the refund, such as a U.S. broker or authorized notify party.

The designated refund receiver must also have:

  • ACE Portal access
  • An applicable Importer sub-account view
  • ACH Refund Authorization completed

For entry summaries, the filer may need to indicate the intended notify party. Some entries may also involve CBP Form 4811, the notify party field, or even a PSC. 

This part can become complicated. Contact Cargo Bridge for further details click here: Cargobridge

Step 7: Identify Which Entries Are Eligible for CAPE Phase 1

CAPE Phase 1 generally covers:

  • Unliquidated entries, and
  • Entries liquidated within the preceding 80 days

You must calculate the 80-day window from the liquidation date, not the entry date.

Example:

If an entry liquidated on March 20 2026, the 80-day deadline is around June 8 2026.

If the entry is more than 80 days past liquidation, CAPE Phase 1 may reject it. Future CAPE phases may address additional categories, but as of now the only think you can do is wait or file a PSC. PSC may do nothing, or it may affect your future refunds. Please consult with your customs broker or attorney for further action.

Step 8: Check for Entries That May Not Be Accepted in CAPE Phase 1

Some entries may not be accepted in current CAPE Phase 1, including:

  • Entries more than 80 days past liquidation
  • Entries covered by an open protest
  • Reconciliation entries
  • Drawback entries
  • Entries for which liquidation is final
  • Certain AD/CVD entries
  • Entries not filed in ACE or without liquidation status in ACE

CBP has stated that some of these categories may be evaluated for later CAPE phases.

If an entry is over 80 days past liquidation but still within 180 days of liquidation, ask your broker or customs attorney whether a protest is needed to preserve rights.

Step 9: Prepare the CAPE CSV File

CAPE is filed through the ACE Portal by uploading a CSV file called a CAPE Declaration.

The file generally contains a list of entry numbers for which IEEPA refunds are requested.

Basic format:

Entry Number
12345678901
23456789012
34567890123

Tips:

  • Use only eligible entry numbers.
  • Use the CBP-provided CAPE template if available in ACE.
  • Do not add extra columns unless the CBP template requires them.
  • Make sure entry numbers are formatted correctly.
  • Save the file as CSV.
  • Keep a copy of the submitted file and confirmation.

Step 10: Submit the CAPE Declaration in ACE

In ACE:

  1. Log into the ACE Portal.
  2. Go to the Importer account, broker account, or filer view that has CAPE access.
  3. Look for the CAPE tab.
  4. If you do not see CAPE, check the More menu.
    5. Go to file uploads, then click "upload"


    6. Click on "CAPE Upload Template" to download a copy of the template. Input your enty numbers into the template and make sure to save as a .csv file. Then click on "acknowledge", drag and drop, or upload your new saved template with entry numbers.

    7. Once the update is complete, check on your upload document status. Click on "file uploads" and you see see a File updated job#. Check your "File Upload Status". It will tell you if you have any errors or if its been accepted.

                    Possible results may include:

      • Accepted
      • Failed initial validation
      • Rejected by batch validation
      • Error report available

    8. Lastly you can check for your claim status in the next tab over "claim status"

    9. Your IEEPA refund is now complete. Please wait 2 - 12 weeks to receive your refund.

Step 11: Monitor the Refund Status

After CAPE submission, monitor ACE reports and refund status.

Useful reports may include:

  • CAPE-related reports
  • REV-603 Trade Refund Report
  • REV-613 ACH Rejected Refunds Report
  • REV-615 CAPE Details Refunds Report

Common refund statuses:

Sent to Treasury
Treasury has received the approved refund claim.

Treasury Issued
Treasury has issued the refund.

Funds Diverted
Some or all funds may have been used to offset an existing debt.

Check/ACH Returned
The refund may have been rejected because of ACH enrollment or banking issues.

If the refund is rejected, check the ACH setup and contact CBP.

Step 12: How Long Does the Refund Take?

CBP’s current public guidance says importers and authorized brokers should generally anticipate valid IEEPA refunds within 60 to 90 days following acceptance of the CAPE Declaration, unless further review or compliance issues apply.


Step 13: Who to Contact for Help

For ACE account login, Top Account, Importer sub-account, or access problems:

Email: ACE.Support@cbp.dhs.gov

For ACE account application issues:

Email: ACE.Applications@cbp.dhs.gov

For technical IEEPA refund questions:

Email: IEEPARefunds@cbp.dhs.gov

For general IEEPA refund questions:

Email: Traderelations@cbp.dhs.gov

When emailing CBP, include:

  • Company legal name
  • Importer number / EIN
  • ACE username/email
  • Entry numbers
  • Liquidation dates
  • CAPE Declaration number, if available
  • Refund number, if available
  • Screenshot of error message
  • Clear explanation of the issue

Sample Email to CBP for IEEPA Refund Technical Question

Subject: IEEPA CAPE Refund Question – Importer [Company Name]

Hello CBP IEEPA Refunds Team,

We are the Importer of Record for the entries listed below and are preparing to submit an IEEPA refund request through CAPE.

Company legal name:
Importer number / EIN:
ACE account email:
Entry numbers:
Liquidation dates:
Issue or question:

Please confirm what steps we should take or whether any additional setup is required.

Thank you.

Final Checklist Before Filing

Before submitting your CAPE Declaration, confirm:

  • The company has an active ACE Portal Top Account.
  • The company has an Importer sub-account.
  • ACH Refund Authorization is completed.
  • The entries include IEEPA duties.
  • The entries are unliquidated or within 80 days of liquidation.
  • The entry numbers are correct.
  • There is no open protest blocking CAPE Phase 1.
  • The CSV file follows the CBP template.
  • You saved proof of submission.
  • You are monitoring ACE reports after submission.

Important Reminder

IEEPA refund rules and CAPE phases may change. Always check CBP’s official IEEPA Duty Refunds page before filing, and consult your customs broker, freight broker, or trade attorney for entries that are protested, final, reconciled, subject to drawback, or past the CAPE Phase 1 deadline.



IEEPA Refund Assistance

Need help reviewing your IEEPA refund eligibility or preparing your ACE/CAPE refund submission?

Cargo Bridge can help importers organize entry lists, check liquidation dates, prepare CAPE CSV files, review ACE/ACH setup steps, and coordinate with customs brokers when needed.

For assistance, contact us at: brian@cargobridgeusa.com or click the link here and leave a message.


Disclaimer: This guide is for general informational purposes only and is not legal advice. Importers should confirm eligibility and filing strategy with CBP, their customs broker, freight broker, or a qualified customs attorney.

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