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IEEPA Tariff Refund Claims

Background​

In 2026, the US Supreme Court struck down the emergency tariffs imposed by the Trump administration under the International Emergency Economic Powers Act (IEEPA). CBP responded by opening the CAPE (Customs Automated Processing Environment) portal within ACE on April 20, 2026, allowing importers to self-file refund claims.

LaParty's exposure:

  • Approximately 200 IEEPA-affected import entries
  • Approximately $1.8M USD in potential refunds
  • Customs broker: Arbor Pak, IOR 0016076266
  • Broker quoted $89/entry ($17,800 total) or 15% of recovery to file on our behalf
  • Decision: self-file. CAPE filing is a straightforward CSV upload — the broker fee is disproportionate. David is filing directly through his own ACE Portal importer account.

Eligibility Rules​

Eligibility for each entry depends on its liquidation status:

StatusEligible?Filing Path
Unliquidated✅ CAPE Phase 1CAPE CSV upload
Liquidated within 80 days✅ CAPE Phase 1CAPE CSV upload
Liquidated more than 80 days ago, less than 180 days⚠️ Formal protest requiredCBP Form 19 (19 USC §1514)
Liquidated more than 180 days ago❌ Not eligible for Phase 1Possible Court of International Trade path

Important: CAPE Phase 2 has no announced timeline. Waiting is risky — move quickly on Phase 1 eligible entries.

Triage Strategy: Three Buckets​

(Decision made April 21, 2026)

All ~200 entries need to be sorted by liquidation status into three buckets before filing anything.

Bucket 1: CAPE-Eligible (Phase 1)​

  • Unliquidated, or liquidated within the last 80 days
  • Action: Add entry numbers to the CAPE CSV template and upload via ACE Portal

Bucket 2: Protest-Eligible (Form 19)​

  • Liquidated more than 80 days ago, but less than 180 days ago
  • Action: File a formal CBP Form 19 protest before the 180-day deadline from liquidation (under 19 USC §1514)
  • Time-sensitive — do not delay

Bucket 3: Potentially Expired / CIT Path​

  • Liquidated more than 180 days ago
  • Action: Assess whether the Court of International Trade path is viable
  • Consider consulting a trade attorney for these entries

Step-by-Step Instructions​

Step 1: Pull Liquidation Data from ACE (ES-003 Report)​

  1. Log into ACE Portal: https://ace.cbp.dhs.gov
  2. Navigate to: Public Folders → ACE → Shared Reports → Trade → Arbor Pak-0016076266 → Importer → Entry Summary → ES-003
  3. Once in ES-003, manually add the following columns (they are not shown by default):
    • Liquidation Status
    • Liquidation Date
  4. Export all ~200 entries
  5. Sort into the three buckets above using a spreadsheet

Step 2: Prepare and Upload the CAPE CSV (Bucket 1)​

  1. Log into ACE Portal and navigate to the CAPE tab
  2. Download the official template: ACEP_CapeEntryNumberUploadTemplate
  3. Fill it out:
    • Row 1 header: Entry Number
    • Row 2 onward: one 11-character alphanumeric entry number per row (dashes optional)
    • Max 9,999 entries per declaration; no duplicates
    • Save as .csv
  4. Upload the completed file via the CAPE tab

Step 3: File Form 19 Protests (Bucket 2)​

  1. Download CBP Form 19 (Protest and Summons)
  2. Complete the form for each affected entry
  3. Submit to the relevant CBP port of entry within 180 days of liquidation
  4. Keep confirmation records of each submission

Step 4: Evaluate CIT Path (Bucket 3, if applicable)​

  • Consult a trade attorney to assess whether a Court of International Trade appeal is viable
  • Document liquidation dates and duty amounts for each entry in this bucket to support legal evaluation

Current Status & Next Actions​

ItemStatus
Navigated to ACE ES-003✅ Done (2026-04-21)
Pulled liquidation date data🔄 In progress — expanding folder
Three-bucket triage⏳ Pending
CAPE CSV upload⏳ Pending
Form 19 protests (if applicable)⏳ Pending assessment
CIT path evaluation (if applicable)⏳ Pending assessment

Reference​

  • Customs broker: Arbor Pak, IOR 0016076266
  • ACE Portal: https://ace.cbp.dhs.gov
  • Statutory basis for protests: 19 USC §1514
  • CAPE portal opened: April 20, 2026

Change Log​

DateUpdate
2026-04-21Initial page created. Self-filing decision made. David successfully navigated to ES-003 and is pulling liquidation dates.
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This is a living document. Update the status table above and add a change log entry each time a step is completed or the situation changes.