The Customs Assessed Payments Eligibility (CAPE) portal is the mechanism Customs and Border Protection stood up after Learning Resources v. Trump to process refunds of the approximately $166 billion in IEEPA-attributable duties it collected from 2018 to 2026. Filing is bounded by a 180-day statutory window from portal open.
This post answers the most common timing questions we get at Tariff Refund Credits:
For the overwhelming majority of importers, the clock started the day CBP announced the CAPE portal open and published the initial filer registration procedure in the Federal Register. There is no per-importer start date — it’s a single statutory window for the entire 330,000-population CAPE cohort.
The full countdown and sub-deadlines are tracked in real time on the CAPE window calculator, which pulls the official close date and returns days remaining.
Inside the 180-day window, three sub-deadlines matter more than the final close:
Licensed customs brokers working under 19 CFR 111 need approximately 60 to 90 days to complete a CAPE filing for a typical mid-market importer. That timeline includes:
If you haven’t engaged a broker by day 30, your filing window starts to compress. By day 60, most broker partners will stop accepting new engagements for the current CAPE cycle.
CBP’s CAPE adjudicators typically request supporting documentation within 30 days of submission. Filings submitted after day 90 often receive their supporting-documentation request after the portal closes, which creates substantial administrative friction. Best practice: have your filing package CBP-submitted by day 90.
The last 30 days of the window are reserved for filings that cannot logistically be completed earlier — typically importers discovered late by outreach, or importers whose broker of record went out of business. Attempting a new filing inside the final 30 days is possible but risky.
On day 181, the CAPE portal closes to new submissions. This is a statutory deadline under the CAPE implementing regulation — not an administrative policy CBP can waive. Day-181 filings are returned unprocessed.
Two narrow exceptions exist:
1. Filings submitted before close but awaiting documentation response. These continue through adjudication past day 180.
2. Filings for importers with a pending 19 U.S.C. § 1520 protest that overlaps the CAPE window. These preserve the statutory remedy separately from CAPE.
Everyone else loses the claim permanently. The duties paid under IEEPA authority remain with Treasury’s General Fund.
Operationally, yes. CBP’s CAPE team is adjudicating on a first-in/first-out queue. Filings submitted in the first 30 days have been clearing in 45 to 60 days and receiving refund via ACH within approximately 90 days of submission. Filings submitted in the final 30 days are projected to clear in 120 to 180 days, post-window.
The financial impact is time-value-of-money — a refund received in month 3 vs. month 9 is meaningfully more valuable to a working-capital-constrained importer.
1. Run the IEEPA refund estimator — 60 seconds, no signup
2. Take the qualification quiz to confirm your entries fall inside CAPE scope
3. Book a 20-minute call with a licensed broker partner
4. Review the CAPE filing checklist for document prep
Related reading:
The CAPE window is a statutory deadline. Missing it means losing the claim permanently. Estimates throughout are preliminary and subject to CBP adjudication. Customs business performed exclusively by broker partners under 19 CFR 111.
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