This is a major milestone. CBP estimates more than 330,000 importers paid roughly $166 billion in IEEPA duties across over 53 million entries before collection stopped on February 24, 2026. Phase 1 of CAPE finally gives those importers a way to claim back what they're owed.
But Gateway Lines is issuing a warning to the trade community alongside the celebration: the launch of CAPE will trigger a wave of refund-recovery scams. Importers need to know who is and isn't legally authorized to file these claims.
Who Can Actually File a CAPE Declaration
CBP's published guidance is unambiguous on this point. Only two parties are permitted to submit a CAPE Declaration through the ACE Portal:
The Importer of Record (IOR) filing directly through their own ACE Portal account
The licensed customs broker who filed the original entries on the IOR's behalf'
That's it. There is no third option.
Who Cannot File — No Matter What They Tell You
In the next several weeks, importers should expect aggressive outreach from companies and individuals offering to "file your IEEPA refund for a fee." Many of these solicitations will come from entities that are not legally authorized to file CAPE Declarations.
Falling for these solicitations doesn't just waste money — it can delay or invalidate your refund.
The following parties cannot file CAPE Declarations on your behalf:
NVOCCs (non-vessel operating common carriers — including Gateway Lines itself)
OFFs (ocean freight forwarders)
3PLs (third-party logistics providers)
Freight forwarders of any kind
Logistics consultants without CBP customs broker licenses
Refund recovery firms that lack a customs broker license
Foreign-based service providers without proper US authorization
Any party using the Automated Broker Interface (ABI) or third-party EDI — CAPE filings must come through the ACE Portal directly
If a freight forwarder, NVOCC, or any non-broker entity offers to file your CAPE Declaration in exchange for a fee, that offer is not legitimate. They cannot legally submit on your behalf. At best, they're acting as a middleman charging you for an introduction. At worst, they're committing fraud.
What Gateway Is Doing About It
Gateway Lines is an FMC-licensed NVOCC and Ocean Freight Forwarder. We are explicitly NOT a licensed customs broker — and we will never claim otherwise. Our role in the CAPE process is to help our customers and the broader importer community navigate the refund landscape transparently.
What Gateway can legitimately do:
AI document analysis — Upload your CF-7501s or broker statements to our IEEPA Refund Calculator for free analysis. Our tools identify IEEPA-eligible entries, estimate your refund (including accrued interest), and generate the CAPE Declaration in the CSV format CBP requires.
Broker referrals — If you don't have an active customs broker, we can introduce you to ClearIt, our licensed customs broker partner, who can file CAPE Declarations on your behalf.
Education and tariff intelligence — We monitor every tariff action affecting our customers and publish ongoing analysis at tariff.gatewaylines.com.
What Gateway will NOT do:
File CAPE Declarations on your behalf (we are not authorized)
Charge fees for IEEPA refund filings (we have no service to charge for)
Promise specific refund timelines or amounts (CBP controls the process)
Offer to act as your customs broker (we are not licensed)
Phase 1 Eligibility — A Quick Reference
For importers checking their own eligibility, Phase 1 of CAPE covers:
Eligible:
Unliquidated entries
Entries within 80 days of liquidation
Suspended, extended, or under-review entries (including warehouse entries, with refunds issued upon liquidation)
Refunds include both IEEPA duties and accrued interest
Excluded from Phase 1:
Entries flagged for reconciliation (Type 09)
Entries with drawback claims (Type 47)
Entries subject to antidumping or countervailing duties with DOC liquidation instructions
Chapter 98 HTSUS entries with entered value on Chapter 98 lines
Entries fully liquidated more than 80 days ago
Entries where surety paid the duty rather than the importer
Entries not filed in ACE or lacking liquidation status in ACE
The 80-day window matters. An entry liquidated on February 15, 2026, for example, loses Phase 1 eligibility around May 6, 2026. After that, importers wait for Phase 2 (no announced timeline) or pursue refunds through litigation at the Court of International Trade.
What to Do Today
If you paid IEEPA duties in 2025, here's the path forward:
Confirm your ACE Portal access — You'll need the Importer sub-account
Enroll in ACH refunds — A refund-specific bank account is required (separate from any duty payment ACH)
Pull your entry list — Identify entries with IEEPA HTS codes (Chapter 99 codes starting 9903.01 or 9903.02)
Coordinate with your customs broker — They are the only party authorized to file your CAPE Declaration if they filed your original entries
Verify any third-party service offers — Confirm the entity is a CBP-licensed customs broker before paying anyone for filing services
If you suspect fraud, report it to CBP at [email protected] or call 1-877-227-5511.
A Note on Trust
Trade compliance is not a place to take shortcuts. The CAPE refund process is new, the rules are evolving, and bad actors will exploit confusion. Gateway Lines built our business on transparency — we tell our customers what we can and cannot do, who we partner with, and where their money goes.
If anyone tells you something different about IEEPA refunds — that they can file for you despite not being a customs broker, that they have a "special relationship" with CBP, that they can guarantee a faster refund for a fee — be skeptical.
The legitimate path is documented above and on CBP's official IEEPA refund page.
Refunds belong to importers. Gateway is here to help you get yours.
Get started: Use the free IEEPA Refund Calculator to analyze your entries and estimate your refund. No fee, no upsell.
Questions: Talk to a Gateway trade expert at gatewaylines.com/speak-with-us.
Below are official sources to help you navigate,
Verify directly with CBP:
Official Sources:
Primary IEEPA refund page: https://www.cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds
IEEPA FAQ page: https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ
Trade Remedies main hub: https://www.cbp.gov/trade/programs-administration/trade-remedies
Official IEEPA Duty Refunds Fact Sheet (CBP PDF): https://www.cbp.gov/document/fact-sheets/fact-sheet-ieepa-duty-refunds
Trade Information Notice on CAPE (CBP guidance PDF): https://www.cbp.gov/document/guidance/trade-information-notice-cape
ACE Portal CAPE Declarations Quick Reference Guide (CBP PDF): https://www.cbp.gov/document/guidance/ace-portal-cape-declarations-quick-reference-guide