The Tariff Refund Suite™ | End-to-End CAPE, Protest, Drawback and Exclusion Recovery

CAPE (Consolidated Administration and Processing of Entries) is CBP’s official IEEPA refund portal, launched April 20, 2026 inside the ACE Secure Data Portal. CAPE accepts a CSV of entry numbers but does not identify eligible entries, calculate refunds, screen Phase 1 eligibility, or track recovery. The Suite handles everything before and after CAPE: identifies your IEEPA-eligible entries, flags which qualify for CAPE Phase 1 right now, prepares the CAPE-ready CSV, and tracks every refund through completion. CBP’s August 5, 2026 court filing shows more than $100 billion already paid out across 17.6 million-plus entries.

CAPE Phase 2 has been live since June 29, 2026. Phase 2 covers entries CAPE Phase 1 left out: entries liquidated more than about 80 days ago, foreign-trade-zone (FTZ) entries including Type 06 withdrawals, drawback-linked entries, and entries flagged for reconciliation. The Suite’s Eligibility Checklist sorts every entry into Phase 1 now, Phase 2 (now live), or alternative pathway automatically. The v2.5 Phase 2 release shipped the moment the portal opened on June 29 already included in your purchase.

CAPE is a submission portal. It accepts entry numbers and processes the refund. It does not do the analysis. Without preparation, importers submit entries that get rejected, miss eligible entries entirely, and have no way to track which refunds have actually paid out. The Suite is the preparation and management layer: eligibility screening, refund calculation, CAPE-ready export, exclusion tracking, protest preparation for entries CAPE does not cover, and a Filing Status Dashboard.

The 10% Section 122 tariff, imposed February 24, 2026 under the Trade Act of 1974 after the Supreme Court struck down IEEPA tariffs, expired July 24, 2026 at its 150-day statutory cap no new Section 122 duties are being collected. Expiration does not cut off refunds: Post-Summary Corrections remain available before liquidation and protests for 180 days after each entry liquidates. The Court of International Trade ruled Section 122 unlawful on May 7, 2026; the Federal Circuit stayed that ruling while the appeal proceeds, so duties collected during the stay may become refundable if the ruling stands. The Suite includes a Section 122 Tracker so every February 24 to July 24 entry is documented and audit-ready.

No. For refund filings, the HTS code is evidence, not an estimate CBP matches your protest or PSC against the code as filed on your CBP Form 7501. So the workbook asks you to copy codes from the same documents your Duty Paid figures come from: your 7501, your ACE Entry Summary report, or your broker’s statement. It is one paste operation, not a memory test. Once the code and country are in, the workbook auto-fills today’s rate, the estimated duty at current rates, and the region the comparison baseline that makes your refund gap visible. Need to research codes for future sourcing decisions? That is what the Tariff Auto-Fill Tool™ (TAF-097) is built for.

Because that is how CBP pays refunds. Duty is assessed per entry (CBP Form 7501), and every refund vehicle CAPE, Post-Summary Correction, protest, drawback is keyed to entry numbers, not product SKUs. One product can appear across many entries at different rates. Tracking at the entry level means the numbers on your generated filing documents reconcile against CBP’s own records which is exactly what keeps a protest from being kicked back.

IEEPA refunds through CBP’s CAPE portal (Phase 1 and Phase 2), Section 301 China tariff exclusion refunds, Section 232 steel and aluminum exclusion refunds, Duty Drawback claims (up to 99% recovery on exported or destroyed goods), CBP protest filings under Form 19, Post-Summary Corrections (PSC) for unliquidated entries, USTR exclusion renewal filings, and Section 122 record-keeping for the next refund wave.

Yes. The Suite is a one-time $197 purchase that includes every future update automatically. No subscription, no upgrade fees, no new SKU when the product changes. Customers who bought in February have received five major updates at no additional cost. The v2.5 Phase 2 release shipped on June 29 and is already included.

No. The workbook uses locked logic for the calculations and editable inputs for your data, so you cannot accidentally break a formula. You enter your entries in the Data Input tab and the rest of the workbook updates automatically. Most teams complete their first refund filing within 60 minutes of opening the Suite. Works in Excel, Google Sheets, and LibreOffice no plugins required.

Trade compliance managers running multi-authority refund programs, customs brokers preparing protest filings and drawback claims for clients, finance controllers recovering overpaid duties to restore margin, procurement directors auditing historical import costs, and CFOs or FPand A teams quantifying recovery impact for board reporting.

Each pathway runs its own clock. A CBP protest must be filed within 180 days of liquidation under 19 U.S.C. §1514. A Post-Summary Correction must be filed before liquidation and no later than 15 days before the scheduled liquidation date. Duty drawback claims run 5 years from the date of import under 19 U.S.C. §1313. Section 301 exclusion refunds are tied to the retroactivity date in the specific Federal Register exclusion notice. Entries generally liquidate 314 days after entry which is why a missed liquidation date is the single most common reason a refund is lost.

It depends on four variables: which tariff authority you paid under, the country of origin, whether the entry has liquidated, and whether the goods were later exported or destroyed. IEEPA duties route to CAPE. Section 301 and 232 exclusion refunds on liquidated entries route to a CBP Form 19 protest. Unliquidated entries with a classification or valuation error route to a PSC. Goods exported or destroyed within 5 years route to drawback. The Filing Path Decision Model applies those four tests to every row automatically.

It is a single self-contained HTML file included free with the Suite. You open it in any browser and import your TRS-197 workbook directly. It reads the Section 301, 232, 122, and Other Remedy tracker tabs, calculates KPIs instantly, assigns each entry a recommended filing action and deadline window, and generates filing-ready documents with one click. All processing happens locally in your browser no workbook contents are transmitted, there is no account, and it runs offline. A one-click Presentation Mode converts the dashboard into a five-slide board-ready deck.

Recovery depends on your entry volume and which authorities you paid under, but the scale is set by the underlying programs. Section 301 List 3 alone covers roughly $200 billion in annual Chinese-origin trade at 25%, and List 4A covers roughly $120 billion at 7.5%. In a representative 30-entry Command Center dataset, $694,243 in duty at risk produced a 61.9% projected recovery rate. Drawback recovers up to 99% of duties paid on goods later exported or destroyed. One Fortune 500 manufacturer recovered $1.2 million in a single quarter using these tools.

Five fields per entry, all of which appear on documents you already hold: the CBP entry number, the entry date, the HTS code as filed, the country of origin, and the duty paid. Every one comes off your CBP Form 7501, your ACE Entry Summary report, or your broker’s statement. You do not need to research or estimate anything. Paste those five columns into the Data Input tab and the workbook fills in current rates, the estimated duty gap, the applicable authority, and the routing decision.

Yes. An importer of record can file its own protests, Post-Summary Corrections, and CAPE submissions directly. Big 4 and specialist customs firms typically charge $15,000 to $35,000 for a refund recovery engagement, or $5,000 and up per individual claim, often plus a contingency percentage of what they recover. The work they do is eligibility screening, refund calculation, document preparation, and status tracking exactly what the Suite systematizes for a one-time $197. Complex classification disputes, binding ruling requests, and anything already under CBP audit still warrant licensed counsel or a broker.

A template pack gives you blank forms. The Suite gives you a connected system. Data enters once on the Data Input tab and flows across 12 tools: eligibility screening against Section 301, 232, 122 and IEEPA, automatic pathway routing, refund calculation, deadline tracking by entry number, CAPE-ready CSV export, a Filing Status Dashboard with ACH reconciliation, and the Executive Interactive Command Center that generates the actual filing documents. Templates cannot tell you which entries qualify, what they are worth, or when the window closes.