IEEPA Refunds
On February 20, 2026, the Supreme Court struck down roughly $166 billion of IEEPA tariffs in V.O.S. Selections, opening one of the largest customs-refund programs in U.S. history. CBP’s refund portal— the Consolidated Administration and Processing of Entries system, or CAPE — launched April 20, 2026. The first tranche of refunds is expected to disburse the week of May 11, 2026, and CBP has stated that valid claims will generally pay within 60 to 90 days after acceptance.
The eligible pool covers roughly 330,000 importers and 53 million entries. Filing has not been straightforward: 19% of first-week CAPE submissions were rejected, almost entirely on preventable data errors. Most importers do not have the in-house resources to file cleanly on the first pass.
Why companies miss it
CAPE filing is not a one-time submission. Most importers face the same three problems:
Fragmented import data
Import data is fragmented across multiple brokers and CBP’s ACE (Automated Commercial Environment) records, leaving no single ledger of duties paid.
Filer code mismatches
The filer code on each original entry must match the broker’s ACE Filer Code exactly — a mismatch is the most common reason CAPE has rejected submissions to date.
The 80-day window
After an entry liquidates, importers have 80 days to file directly into CAPE; past that point, the claim is preserved only by filing a §1514 protest through trade counsel.
Without specialized resources and a defined process, the claim window closes and the entry is permanently barred. Claims recovery is the only thing Dynamic Settlement Group (DSG) does — it is the reason we built the firm.
How DSG runs the process
DSG operates as the importer’s advisor and funds intermediary, sitting between the importer of record and the original-filer broker. We handle the work from data reconstruction through refund disbursement, so your finance, legal, and operations teams stay focused on the business. Our work includes:
Reconstruct the import record
Reconstructing the import record from ACE entry summaries and broker files, flagging every entry eligible under V.O.S. Selections
Reconcile & file through CAPE
Reconciling filer codes against the broker’s ACE Filer Code, then coordinating each CAPE Declaration through the original-filer broker—the step that fails most often when importers attempt the filing in-house
Preserve claims via §1514
Preparing §1514 protests through trade counsel for entries past the 80-day window, preserving claims that would otherwise lapse
Route refunds via Form 4811
Routing refund receipt and disbursement through CBP Form 4811.
Our engagement is contingency-based: DSG is paid only from refunds we successfully recover.
CAPE Phase 1 currently covers roughly 63% of IEEPA-affected entries — those still unliquidated and those liquidated within the preceding 80 days. That share shrinks every day Phase 1 runs, and CBP has not yet published Phase 2 timing for finally liquidated entries. Most companies with active imports during the affected period have refundable duties in the Phase 1 pool.
A 20-minute call can establish:
- Whether your entries fall within Phase 1 eligibility
- An estimate of recoverable duty
- A path forward that does not pull your internal finance, legal, or compliance teams off other work
DSG works alongside internal finance and legal teams and outside counsel as the single point of accountability for the recovery. We would welcome the opportunity to provide a confidential, no-obligation assessment.