As of August 25, 2026, CBP is still taking IEEPA refund claims through CAPE in ACE. There is not one calendar date when “the window closes” for your company. Each entry has its own clock, tied to that entry's liquidation.
If you paid IEEPA duties, the useful work this week is an ACE inventory: which entries are still unliquidated, which liquidated in the last 80 days, which are already final, and whether a protest clock is running. Then pick the rung that actually fits that entry.
The ladder, as of this date
CAPE first. CBP built Consolidated Administration and Processing of Entries so IEEPA refunds can be requested in the ACE Portal with a CSV of entry numbers (a CAPE Declaration), not by filing a Post Summary Correction. CBP's Phase 1 Trade Information Notice and the live IEEPA Duty Refunds page are the rules of the road. CBP states that the trade is prohibited from initiating an IEEPA refund by PSC.
Phase 1 (live since April 20, 2026) covers most entries that are unliquidated, or liquidated within the preceding 80 days. CBP set the 80-day cut so it can still reliquidate inside the 90-day voluntary-reliquidation period in 19 U.S.C. § 1501. Suspended, extended, or under-review entries, and warehouse / warehouse-withdrawal entries, may go on a Phase 1 declaration; they keep their liquidation status until that status resolves, and any validated refund follows liquidation.
Phase 2 (effective June 29, 2026) added entries flagged for reconciliation (types 01, 02, 06) when the type 09 reconciliation is not yet on file, still limited to unliquidated or within 80 days of liquidation. Once those flagged entries are accepted on a CAPE declaration, the trade may file the reconciliation. If the type 09 is already on file, CBP says that bucket is a later phase. If a recon deadline is inside about 30 days, CBP tells the trade to prioritize the reconciliation.
Form 19 protest next, when CAPE will not take the entry. A protest under 19 U.S.C. § 1514 is generally due within 180 days of liquidation. That is a different clock than CAPE's 80 days. An entry can be too late for Phase 1 CAPE and still inside the protest window. CBP's own FAQ: if you disagree with the refund amount after CAPE liquidation or reliquidation, a protest is the path they name.
CIT if you need a court path. CBP's FAQ (updated May 20, 2026) says you do not need a CIT case for Phase 1 (unliquidated or still inside the 90-day voluntary-reliquidation period). For other entries, CBP offers no legal guidance. We will not tell you the refund is gone. Finally liquidated entries, drawback, open protests, non-ACE entries, and certain AD/CVD entries are on CBP's “subsequent phases” list as of the July 20, 2026 page update. Whether you also need a court filing is a question for counsel on those facts — see our note on CIT orders.
What “too late” actually looks like
In ACE, a Phase 1/2 reject that reads “Entry Summary is in Final Liquidation Status” means CBP's current CAPE build will not take that line: liquidation or reliquidation was more than 80 days ago.
That is not the same as “no path.” Check, in order:
- Is the 180-day protest window still open on that liquidation date?
- Is the entry in a bucket CBP has already said is a later CAPE phase (recon already on file, drawback, open protest, not in ACE, final liquidation)?
- Is there an individual CIT posture that applies to your IOR, not someone else's case?
Do not file a PSC to “start” the IEEPA claim. CBP barred that. PSC remains a tool for ordinary pre-liquidation fixes (class, value, other programs) — and CBP says if you need a non-IEEPA PSC, file it before you put the entry on a CAPE declaration. Once a declaration is accepted, CBP says you cannot pull those entries off it or cancel it.
Build the ACE inventory before you file anything
For each IEEPA entry, write down:
- Entry number and filer code
- Liquidation status and liquidation date (or “not liquidated”)
- Whether a type 09 recon is flagged or already on file
- Whether a protest or drawback already sits on it
- Whether the line actually carried a dutiable IEEPA Chapter 99 HTS (CAPE will reject “No IEEPA HTS on Entry”)
Then the three setup items CBP will not waive:
- An ACE Portal account (Importer sub-account if you want to watch refunds yourself)
- ACH refund bank information on file (this is not the ACH debit you use to pay CBP)
- A filer who is allowed to submit: the IOR, or the licensed broker who filed those entries. CBP's FAQ: an attorney cannot file the declaration. ABI cannot file it. A later broker who did not file the original entries cannot file it either.
CBP will issue refunds only to the IOR or a Form 4811 notify party, by ACH. CBP does not charge a government fee for the refund; anyone asking you to pay “CBP” is a scam (CBP's words).
Accepted declarations cannot be amended. Extra eligible entries go on a new declaration. Each entry may appear on only one accepted declaration. Cap is 9,999 entries per file (CBP's error table also mentions a 10,000-line file limit — stay under the TIN's 9,999).
CBP's public estimate: valid refunds are generally issued 60–90 days after acceptance, unless review, extension, suspension, or warehouse status delays liquidation. That is CBP's timing, not a promise from us. Amounts can net other duties still due on the same entry (301, 232, Column 1, etc.). A CAPE result can even be a bill if the rest of the entry was underpaid.
How this runs into 2027 without a single “2027 deadline”
Entries filed in late 2025 and through 2026 will keep liquidating on their own schedules. Each time one liquidates, a new 80-day CAPE clock and a 180-day protest clock start for that number. So you will still be doing this work in 2027 for later liquidations. Treat it as a tracker, not a one-day fire drill.
What to do this week
- Pull ACE liquidation status for every IEEPA entry.
- Sort: CAPE-eligible now / protest-only / later phase or counsel.
- Enroll or confirm ACH refunds before you expect a deposit.
- If you are not the original filer, get the IOR or that filer to submit. We can prep the list; we do not submit as broker of record on someone else's filings.
How we help: we consult on which rung each entry is on, comply on the ACE package and ACH setup, and stay out of the way of the IOR or original filer who has to clear the upload. We do not promise CBP will accept the declaration or pay a given amount.
If you want a second set of eyes on the inventory, start on the CAPE eligibility review. For ordinary pre-liquidation corrections that are not an IEEPA claim, see Post Summary Corrections.
For the court track as of earlier this year, see CIT orders on IEEPA refunds.