CAPE Phase 1 Is Live: What GM's $500M Refund Tells You About Your Own

Three weeks ago, CBP’s CAPE refund portal was a CSV format and a target launch date. As of April 20, it is the dedicated electronic mechanism for Phase 1 IEEPA refund declarations, and the first wave of corporate disclosures is now in: GM booked a $500 million refund into its Q1 numbers on Tuesday, while FedEx, UPS, and DHL publicly committed to passing tariff refunds back to customers as the U.S. government begins returning the levies the Supreme Court invalidated.

What changed in the past nine days is operational reality: a launched portal, a Phase 1 scope estimated by Holland & Knight to capture about 63% of affected entries, a 60–90 day post-acceptance refund window, and corporate examples that put concrete numbers behind the question every importer and broker should be asking — am I set up to receive this money, or am I about to find out I’m not?

What Phase 1 Actually Captures (and What It Doesn’t)

CBP launched Phase 1 of CAPE on April 20, 2026, inside the ACE Secure Data Portal. The scope is narrower than many importers assume.

Phase 1 covers certain unliquidated entries plus certain entries liquidated within the prior 80 days. According to Holland & Knight’s analysis, this captures roughly 63% of the affected entries. Filing happens through a CSV “CAPE Declaration” uploaded to the new CAPE tab in ACE — up to 9,999 entries per declaration, multiple declarations allowed.

Phase 1 excludes entries flagged for reconciliation (Type 09), drawback-claim entries (Type 47), AD/CVD entries pending liquidation under Commerce instructions, and older liquidated entries that fall outside the 80-day window. CBP has not announced firm Phase 2 dates.

The practical implication: importers with mixed entry portfolios may have one bucket of refunds processing in the published 60–90 day window and another bucket waiting on later phases. Knowing which bucket each entry falls into before you file is the difference between a clean Phase 1 submission and a declaration that gets partially rejected on entry-level validation.

What the GM, UPS, and FedEx Disclosures Actually Tell You

The April 28 corporate readouts are the first concrete look at how large filers are treating CAPE refunds operationally and on the books. Three signals from the disclosures matter for your own planning:

GM is treating the refund as a receivable, not as cash. CFO Paul Jacobson told the Q1 earnings call that GM expects $500 million in IEEPA refunds and is crediting the funds as a receivable, but did not change free cash flow guidance because refund timing remains uncertain. The same Q1 disclosure flagged a $200 million Q1 tariff bill — and that figure already nets the assumed $500 million refund. The underlying tariff burden is heavier than the headline. GM still projects $2.5–3.5 billion in 2026 duty costs, primarily from Section 232 levies on steel and aluminum that are not part of the IEEPA refund process.

UPS quantified its passthrough exposure at ~$5 billion in tariffs collected from customers. CEO Carol Tomé disclosed the figure on the post-earnings call. UPS’s published guidance specifies that as the IOR for those shipments, it will request refunds from CBP and reimburse customers once funds are received from CBP, with no pre-funding of customer reimbursements.

FedEx is filing where it served as customs broker, not just as IOR. Per FedEx’s published statement, it began submitting CAPE Declarations for Phase 1-eligible entries on which it served as customs broker and will pass refunds to “the shippers and consumers who originally bore those charges.” For shippers who used FedEx or UPS as their broker rather than as IOR, this is the relevant pathway. CBP issues refunds to the IOR or a Form 4811 designee, after which brokers and carriers handle the downstream reimbursement to customers.

The pattern across all three: large filers are positioning publicly to receive money but managing expectations on timing. None of the disclosures committed to a payment date for end customers because none of the filers control when CBP releases the consolidated refund.

Three Workflow Gaps That Can Delay Your Refund

Most of the operational risk in CAPE Phase 1 is not in the legal eligibility — it is in three configuration and data gaps that cause CBP to either reject the declaration or hold the funds in reject status.

1. ACH refund enrollment is separate from ACH duty payment enrollment. Many importers who pay duties electronically assume they are also set up to receive refunds. They are not. Per Troutman Pepper Locke’s CAPE guidance, CBP requires a refund-specific bank account designation and will hold funds in reject status until valid ACH refund banking is provided. This is a fix in the ACE Importer sub-account that takes minutes — but if it is not done, the refund stops here regardless of how clean the declaration was.

2. Filer authority is tied to who filed the original entry. Refund rights belong to the importer of record, but CAPE Declarations are submitted through ACE by the IOR or the licensed customs broker that filed the underlying entry. If you used multiple brokers across different ports, filing authority for each entry sits with the broker who cleared it — not whichever broker you currently work with most. CBP Form 4811 lets the IOR designate where refunds are routed, but it does not change who is authorized to file the declaration. Importers with distributed brokerage relationships need to map this out before filing.

3. Data validation rejects on entry-level errors, not declaration-level errors. ACE runs two validation passes: file format first, then entry-by-entry validation against ACE records (entry exists, has at least one IEEPA Chapter 99 HTS code declared, no duplicate entry numbers across declarations). Failed entries get rejected individually while the rest of the declaration processes. Resubmissions need to avoid the duplicate-entry trap, and importers need to track which specific entries got bounced so they do not get lost between declaration cycles.

If you are managing IEEPA refund exposure across hundreds of containers and multiple brokers, the bottleneck is not legal — it is reconciling which entry numbers correspond to which shipments, which brokers filed them, and which liquidation status they currently hold. Walk through how visibility teams cross-reference shipment-level data to entry numbers in a 30-minute conversation.

Refund Math: 60–90 Days Plus Statutory Interest

CBP’s published guidance is that valid IEEPA refunds will generally be issued within 60–90 days following acceptance of the CAPE Declaration. That window includes roughly 45 days for CBP review plus Treasury processing time, per the CBP webinar overview published April 17. Carriers and other filers have echoed the same 60–90 day framing in their customer-facing guidance, with the explicit caveat that they cannot pass refunds through to customers until CBP funds reach the filer.

Refunds carry statutory interest under 19 U.S.C. § 1505(c), running from the date of original duty payment through liquidation or reliquidation. For the quarter beginning January 1, 2026, the applicable overpayment interest rates are 7% for noncorporate filers and 6% for corporate filers, per Holland & Knight. For an importer who paid IEEPA duties in mid-2025, the interest component on a multi-million-dollar refund is meaningful — not a rounding error.

For Q2 cash-flow planning, two practical effects to factor in. First, the 60–90 day clock starts at CBP’s acceptance of the declaration, not at filing — declarations that fail validation reset the clock on the rejected entries when resubmitted. Second, for pass-through cases, the customer’s clock starts when the broker or carrier receives funds from CBP, with additional time after that for the filer’s internal reimbursement workflow.

What CAPE Doesn’t Touch: Section 232 and the Replacement Tariffs

This is where reading the GM disclosure carefully matters. The $500 million refund is for IEEPA duties only. GM’s ongoing $2.5–3.5 billion 2026 tariff exposure sits in Section 232 levies on steel and aluminum, which the Supreme Court did not address. Those tariffs remain in force, are not refundable through CAPE, and will not be retroactively unwound.

The same logic applies to the 10% Section 122 tariff that replaced IEEPA effective February 24, 2026, and to existing Section 301 China duties. CAPE’s recalculation removes only the IEEPA Chapter 99 HTS lines from each entry; everything else stays. For entries filed on or after February 24, the Section 122 layer remains payable even after CAPE processes the IEEPA refund.

The clean way to read your own exposure: the IEEPA refund is recoverable cash that was always going to be returned once the legal authority was struck down. Section 232, Section 301, and Section 122 duties on current imports are the real run-rate cost and need to be priced into Q2 contracts and routing decisions independent of any refund inflow.

Decision Brief: What to Do This Week

If you are an IOR: Confirm ACH refund enrollment is active in your ACE Importer sub-account today. Pull a list of every entry where IEEPA duties were paid and bucket by liquidation status. For entries inside Phase 1 scope, prepare your CAPE Declaration CSV and either file directly or coordinate with the broker who originally filed each entry.

If you are a customs broker or freight forwarder: Identify which clients used you as IOR versus broker-only, since your filing authority differs across those entries. Communicate to clients now about ACH enrollment status — CBP cannot release funds until the IOR’s ACH refund banking is set, regardless of who files the declaration. Set fee expectations explicitly before clients see what other brokers are charging.

If you sourced through a parcel carrier (FedEx, UPS, DHL): Your refund flows through their published process. Their published statements indicate no action is required from individual customers — but verify your customer record reflects the correct shipper-of-record details, since reimbursements key off the original payor of the tariff line item.

What to Watch

Phase 1 first refund payments. The earliest CAPE Declarations were filed the week of April 20. The first refund disbursements will give the first real read on actual versus published timeline.
Phase 2 scope and timing. CBP has not announced when reconciliation entries, drawback-claim entries, and older liquidated entries will be addressed. For importers with significant exposure in those categories, this is the next major operational date.
Section 122 litigation. The replacement 10% tariff under Section 122 of the Trade Act is facing legal challenges. A ruling against Section 122 would create a second wave of refund-eligible duties paid since February 24.
Pass-through litigation pressure. Plaintiffs’ firms have begun pursuing claims against importers who passed tariff costs to downstream buyers. Companies that publicly attributed price increases to tariffs face the most exposure.