CAPE Phase 1 is live. Entries liquidated within 80 days qualify now. Entries between 80–180 days: protest deadlines are running. Some expire this week. Upload ACE data →
IEEPA Tariff Refund Recovery · CAPE Phase 1 Now Open

The preparation is where filings fail. RefundDesk handles the preparation.

Upload your ACE entry data. RefundDesk classifies every entry by filing path — CAPE Phase 1, protest preservation, or Phase 2 hold — and shows you every client, their estimated recovery, and their deadline status before you pay anything. Filing packages unlock when you’re ready. Every attestation freezes a complete snapshot at the moment you sign. If CBP guidance changes after you file, your record reflects what the rules were when you attested.

Your data stays yours — never shared with third parties, encrypted in transit. Privacy policy →

Questions? hello@refunddesk.app — you'll hear directly from the founder.

80 Days before an entry exits permanently CAPE Phase 1 accepts entries liquidated within the preceding 80 days — a rolling window. Every week, older entries age out. There is no extension.
$127B Phase 1 pool of eligible duties CBP court filing, April 2026. Phase 1 covers ~63% of affected entries. Every dollar requires a compliant filing to recover.
+6–7% Statutory interest added automatically on every refund CBP calculates interest under 19 U.S.C. §1505(c) from the date duties were paid through reliquidation, at the IRS quarterly rate. RefundDesk estimates this per entry so your client sees their full expected recovery before you file.
Frozen Every attestation locks the record at the moment you sign If CBP guidance changes after you file, your record reflects what the rules were when you attested — not what they are now. That snapshot is never modified.

On February 20, 2026, the Supreme Court ruled 6-3 that IEEPA tariffs were unlawful. CBP stopped collecting them four days later. But refunds aren’t automatic. Every dollar requires a compliant filing. That’s the window you’re in right now.

The ruling in Learning Resources, Inc. v. Trump invalidated the tariffs. It did not instruct CBP to issue refunds. The mechanism for recovery is a broker-filed claim, either through CAPE Phase 1 (launched April 20, 2026) or through the protest process under 19 U.S.C. §1514. No filing, no refund.

CAPE Phase 1 is the faster path. CBP auto-reliquidates qualifying entries with no protest required. The window is 80 days from the date of liquidation, rolling — that's the portal intake deadline. CBP's underlying statutory authority runs 90 days; the portal shows 80 because CBP reserves 10 days for internal processing. An entry at day 81–89 may still be within the statutory window — file immediately if you're in that range. Entries that have aged past that window but were liquidated within 180 days can still be recovered through a formal protest — a longer process, but still a viable path.

Every week, the oldest entries exit the CAPE window permanently. They don't move to a queue. For a client with entries spread across months, some are already gone from Phase 1. The window isn't closing on a single date. It's closing entry by entry.

To qualify, an importer must have paid IEEPA-specific duties, identifiable by an IEEPA HTS Chapter 99 code on the entry. They must be enrolled in ACH for CBP to pay electronically. Entries with AD/CVD codes or reconciliation flags are excluded from Phase 1. Only the IEEPA-incremental portion is refundable — Section 301, Section 232, and the Section 122 10% baseline tariff are separate legal authorities and are not part of this proceeding.

One more thing: June 7 is the last day the Trump administration can petition the Supreme Court to reconsider the ruling — not a filing deadline. The CAPE window runs on liquidation dates. File based on your clients' entry data.

The situation

Your clients are calling.
Show up with their tariff-refund filing ready.

Every importer you filed for between early 2025 and February 2026 who paid IEEPA duties may be owed a significant refund. Recoverable duties range from $50K–$500K+ for an SMB with meaningful import volume. Real capital their business has already absorbed.

CBP is not issuing automatic refunds.

The importer (or their authorized broker) must file. Doing it manually means hours of preparation — and a single formatting error can take down your entire submission. One thing to verify first: if your client imported under Delivered Duty Paid (DDP) terms, a freight carrier may be listed as Importer of Record — and CBP refunds go to whoever is on the entry as IOR. Check the CF-7501 before filing.

RefundDesk handles the preparation.
You review, attest, and file.
Your clients get their refund.

Entries aging out of the CAPE window this week shift to the protest path, or close permanently. Create an account →

Hours of manual preparation. Or ten minutes.

The preparation is where filings fail. Entry classification, liquidation date lookups, ACH confirmation, CSV formatting to CBP spec — done manually, this takes 8 to 15 hours per client. RefundDesk compresses that to under ten minutes.

Without RefundDesk
·ACE export into Excel
·Manual liquidation date classification per entry
·CSV hand-built to CBP's field specification
·Formatting error on submission
·Portal rejects the file — start over, now closer to the deadline
8–15 hours per client No audit trail. No client summary. No confirmation that CBP can even pay you.
✓ With RefundDesk
Upload ACE export
Entries classified automatically by path and deadline
ACH enrollment requirement surfaced before you attest
Review output entry by entry — logic shown, not hidden
Attest and download all four documents
Upload CAPE Declaration CSV directly to ACE
In under 10 minutes per client Filing-ready output, client summary, and a complete compliance record. All from one upload.

The filing package a compliance specialist would hand you, ready in 10 minutes.

4 filing-ready documents. Every client. Every deadline. One upload.

For you to file
CAPE Declaration CSV
Portal-ready, validated against CBP's April 2026 specification. Classified by filing path. Direct upload to the CAPE tab in ACE. No reformatting required. Once CBP accepts a Declaration, it cannot be amended — additional entries require a separate filing. RefundDesk prompts you to confirm completeness before you attest.
For your client
Client Summary PDF
Hand this to your client. Their entries, their estimated recovery with statutory interest, what was filed, and what to expect. Professional. Specific. Done.
For your records
Filing Record PDF
Your compliance retention document per 19 CFR §111.23. Attestation timestamp, entry data reviewed, classification basis per entry. If CBP flags an entry at validation, this is your reference for why it was classified as it was.
Your reference
Entry Schedule CSV
The underlying entry data behind your filing — every entry, its path, its deadline, and the statutory basis for each classification. Your internal reference, separate from the Client Summary your client receives.
Your License.
Your Attestation.
RefundDesk handles the preparation.

You review the output and sign off. Nothing generates until you attest — and you are the broker of record on every filing.
Logic Shown,
Not Hidden
Every entry shows its filing path, liquidation deadline, and the statutory basis for its classification (CAPE auto-reliquidation, voluntary reliquidation window, or protest under 19 U.S.C. §1514) before you attest. The routing logic and the rule it applied are shown for every entry. Nothing is assumed.
Verified Against
Live CAPE Spec
The CAPE Declaration CSV is validated against CBP's April 2026 portal specification before you download — field structure, entry number format, column order. The formatting errors that cause silent portal rejections are caught before you submit, not after.
Post-Filing
Reference
Error codes, ACE report tracking, and common rejection causes, documented in plain language for when you're mid-process and need an answer fast. Free. No login required. CAPE Filing Reference →

Early access. Onboarded personally.

Per client
$997
per importer client (IOR)
For brokers with 1–4 qualifying clients. Includes CAPE Declaration CSV, Filing Record, Client Summary, and Entry Schedule.

RefundDesk is in early access. The first brokers through the product are being onboarded personally. If you have entries in the window and want to talk first:

hello@refunddesk.app →

Built for the IEEPA window. Built to last past it.

RefundDesk is the first product from CrossBorder OS. It was built for licensed U.S. customs brokers filing IEEPA tariff refund claims through CBP’s CAPE portal.

The IEEPA window created an unusual situation: a high-stakes, time-sensitive filing obligation that landed simultaneously on every broker with an active importer client base. The preparation burden is real. The documentation standard is professional. The deadlines are not uniform — they vary entry by entry, and some are already past.

Every attestation freezes a complete record at the exact moment you sign: the duty principal, the interest calculation, the rate source, the IEEPA prefix set, and the eligibility classification that governed the filing. That record is never modified. If CBP guidance changes after you file, your record reflects what the rules were when you attested — not what they are now.

The IEEPA window is the reason we exist right now. The infrastructure we built to handle it — auditability, policy versioning, frozen attestation records — is the foundation for what comes next. Independent brokers and small-firm practices should have access to the same quality of documentation and defensibility as enterprise trade compliance teams. That’s the longer work. This is the beginning of it.

Questions or anything that doesn't look right: hello@refunddesk.app — you’ll hear directly from the founder.

Common questions about IEEPA refund claims

CAPE — CBP's system for processing IEEPA tariff refund claims within ACE — works in four stages. Brokers or IORs submit a CAPE Declaration through the CAPE tab in ACE. CBP validates entries, strips IEEPA duty codes, recalculates what's owed, and reliquidates. Phase 1 launched April 20, 2026. It covers unliquidated entries and entries within the 90-day voluntary reliquidation window. CBP targets up to 45 days to process a validated declaration.

Through the CAPE tab in your ACE Portal account — upload a CSV of entry numbers, CBP validates each entry, and eligible entries are reliquidated with IEEPA duties removed. To be eligible, entries must have had IEEPA duties actually paid and carry an IEEPA-specific HTS Chapter 99 code. Only the IOR or the broker who originally filed the entry can submit.

It depends on when your entries liquidated. For CAPE Phase 1, ACE accepts entries liquidated within the preceding 80 days — a rolling window. For entries liquidated more than 80 days ago, the protest path under 19 U.S.C. §1514 applies, with a 180-day deadline from liquidation. There is no extension mechanism for either path. Entries that have passed the 180-day protest window may still be within the 2-year Court of International Trade statute — that path requires legal counsel. RefundDesk identifies which zone applies to each entry in your triage view.

CAPE covers entries that have not yet liquidated, plus entries that liquidated within the past 80 days. Protest covers entries that liquidated more than 80 days ago but within 180 days — after that, the window closes entirely. A single client's entries may split across both paths. RefundDesk classifies each entry automatically so you can see which path applies. CAPE output is generated for filing. Protest-path entries are identified and flagged for your separate filing.

ACH registration is how CBP disburses refunds. Without it, no payment can be made — even if your filing is approved. Refunds held for missing ACH accrue no interest. ACH set up for duty payments is not sufficient — refund-specific ACH enrollment is a separate step in the importer's ACE sub-account. RefundDesk surfaces ACH enrollment as a required pre-attestation checklist item. Confirmation that enrollment is complete in ACE remains the broker’s responsibility.

After filing, CBP processes validated declarations and reliquidates eligible entries — CBP targets up to 45 days. To track status, use the ESO 22 report in ACE to monitor entry processing status. Cross-reference with REV 603 and REV 615 to reconcile Treasury deposits once refunds are transmitted. Common post-filing issues — rounding rejections, HTS sequence errors, center ID pending codes — are documented in the CAPE Filing Reference →.

No — RefundDesk prepares your filing documents. You review, attest, and file under your own license through ACE. Your license, your client relationship, and your filing responsibility remain entirely with you.

A CSV export from your ABI system or ACE portal covering entries on which IEEPA duties were actually paid. RefundDesk requires seven columns: Entry Number, Entry Date, Liquidation Date, Liquidation Status, HTS Code, Chapter 99, and Duty Paid.

Yes — CBP allows IORs to file CAPE Declarations directly through ACE. RefundDesk works the same way: upload your entry data, generate the CAPE Declaration CSV, and upload to the CAPE tab in ACE. One limitation: if a broker filed your entries, only that broker can submit the CAPE Declaration for those entries.

Phase 1 covers unliquidated entries and entries liquidated within 80 days. Entries outside that window — including reconciliation entries, AD/CVD entries with issued liquidation instructions, and entries more than 80 days past liquidation — are excluded from Phase 1. CBP has confirmed these will be addressed in a subsequent phase but has not announced a launch date, stating only that Phase 2 will launch "as soon as ready." RefundDesk will support Phase 2 filings when CBP launches. For now, entries excluded from Phase 1 are flagged in your triage view with their reason.

The attestation snapshot RefundDesk creates reflects the rules, rates, and eligibility logic at the exact moment you signed. That record does not change. If guidance shifts after you file, your filing is documented against what was knowable when you attested — not what the rules are now.

80-day CAPE filing window · CBP reserves 10 days of the 90-day statutory period

See what your client book is owed.

Entries age out on a rolling 80-day window. Start now. No payment until you're ready to file.

Upload your ACE data →