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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On April 14, 2026, U.S. Court of International Trade Senior Judge Richard Eaton held a closed conference in the new lead case, Euro-Notions Florida, Inc. v. U.S. Customs and Border Protection, et al., addressing refunds of duties paid under the International Emergency Economic Powers Act (&ldquo;IEEPA&rdquo;).&nbsp; At the conclusion of the conference, the Judge issued an <a href="https://storage.courtlistener.com/recap/gov.uscourts.cit.17610/gov.uscourts.cit.17610.19.0.pdf">Order</a> confirming that Customs and Border Protection (&ldquo;CBP&rdquo;) &ldquo;is on track&rdquo; to launch Phase 1 of the Consolidated Administration and Processing of Entries (&ldquo;CAPE&rdquo;) portal on April 20, 2026. The order references CBP&rsquo;s published instructions regarding CAPE Phase 1 (see Thompson Hine Update of <a href="https://www.thompsonhinesmartrade.com/2026/04/cbp-confirms-april-20-2026-launch-of-phase-1-of-the-ieepa-tariff-refund-process/">April 10, 2026</a>), noting that &ldquo;the instructions do not limit the use of CAPE to those claimants who have commenced an action in this Court.&rdquo;&nbsp; The Order also states that &ldquo;Importers should be aware that, by voluntarily using CAPE, any IEEPA cash deposits will be available to offset amounts owed with respect to other duties. Customs will provide a method for identifying entries for which an adjustment has been made.&rdquo;&nbsp;
The Order also references the most recent <a href="https://filehost.thompsonhine.com/uploads/CBP_Delaration_-_April_14_2026_3855.pdf">declaration submitted by Brandon Lord</a>, Executive Director of the Trade Programs Directorate within CBP.&nbsp;According to that declaration, as of April 14, &ldquo;CBP has completed the primary development of all components and functionalities for CAPE [Consolidated Administration and Processing of Entries] Phase 1. The agency has transitioned to an intensive testing posture, focused on performance and scenario-based testing of all CAPE components and the remediation of any defects identified during testing.&rdquo;
The declaration provides a brief update on the status of each of the four components of CAPE, noting that each component is between 85% and 90% complete.&nbsp; See Thompson Hine Update of <a href="https://www.thompsonhinesmartrade.com/2026/03/cbp-reports-progress-on-ieepa-tariff-refund-process/">March 13, 2026</a> for details on each CAPE component.&nbsp; According to Lord, as of April 9, 2026, 56,497 importers of record (&ldquo;IORs&rdquo;) have completed the electronic refund enrollment process required for IORs to receive refunds for their IEEPA entries.&nbsp; For more information on this process, see Thompson Hine Update of <a href="https://www.thompsonhinesmartrade.com/2026/01/cbp-to-issue-all-refunds-electronically-starting-february-6-2026/">January 6, 2026</a>. &nbsp;In total, it is estimated that refunds can be issued electronically for approximately 82% of entries with IEEPA duty payments and/or duty deposits.
Lord indicated that CBP continues to consider options for pre-liquidation refunds for suspended entries subject to antidumping and/or countervailing duty (&ldquo;AD/CVD&rdquo;) orders.&nbsp; Pre-liquidation refunds, also known as administrative refunds, occur before liquidation and involve manual processing, requiring CBP to manually adjust the collection record in ACE, move funds to suspense accounts, and generate manual refunds. This will &ldquo;dramatically increas[e] the workload&rdquo; of CBP officials and, while unstated in the declaration, will likely result in delays in IEEPA refunds within this category.
CBP must file its next update on CAPE and IEEPA refunds on April 28, 2026, the same date on which Judge Eaton will hold a closed settlement conference.

CBP Provides CIT Latest Updates on IEEPA Tariff Refunds

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