The US government’s tariff refund portal opened on April 20, and, against widespread skepticism, mostly works. But for fashion and beauty brands now racing to recover their share of the estimated $166 billion in invalidated International Emergency Economic Powers Act (IEEPA) duties, after a February Supreme Court ruling, the launch of US Customs and Border Protection’s (CBP) Consolidated Administration and Processing of Entries system, known as CAPE, marks the beginning of a far messier phase: navigating hidden eligibility gaps, unresolved technical errors, mounting legal exposure, and a reimbursement process that increasingly favors companies with the infrastructure to survive it.
The first refunds are expected to hit importer accounts as early as May 12, according to CBP. As of April 26, the agency had processed more than 11 million entries, with approximately 1.7 million already liquidated — meaning customs has finalized and closed the entries — and placed into the refund queue. By those measures, CAPE is doing what it was designed to do, especially for Phase 1, which covers only certain eligible entries.
“I am shocked at how easy it is,” says Angela Santos, partner and customs practice leader at Arentfox Schiff, who has been guiding clients through the filing process since the portal opened. “But I say that with some caveats.”
What’s working and what’s not
For well-prepared filers — those with customs counsel, clean entry data, and Automated Commercial Environment (ACE) accounts already in place — the portal process itself is streamlined. Uploading a CSV file takes seconds; approval or rejection follows almost immediately. CBP reports a rough 15% rejection rate across submitted claims — a notable figure even as the agency maintains the system is functioning smoothly — with most rejected submissions stemming from ineligible entries being included rather than outright system failures.
Even so, the process is in its early stages. According to the Fragrance Creators Association (FCA) trade group, only 21% of submitted entries had cleared validation during CAPE’s first week, with roughly 3% reaching the refund stage. Common errors include entries outside the 80-day post-liquidation window — CBP gave itself a 10-day buffer against the 90-day statutory period — as well as entries flagged for reconciliation, drawback programs, or certain anti-dumping and countervailing duty cases.
That distinction matters because some of the most significant complications are not technical failures so much as structural ones embedded in the customs system itself. Reconciliation — a customs mechanism used by companies importing from related parties that finalize product valuation after year-end accounting closes — has emerged as one of the biggest hidden friction points in the recovery process.
What appears straightforward on the surface becomes considerably more complicated once companies begin pulling together the underlying data. “It’s not just ‘uploading a file’,” says Jackson Wood, director of industry strategy for global trade intelligence at Descartes. “The file must be compiled by sifting through significant amounts of business data, verifying and validating that data, and ultimately having the infrastructure set up — ACE account, or Automated Clearing House (ACH) payment mechanism — to facilitate the process.”
That infrastructure requirement is where smaller and mid-sized brands are beginning to hit a wall. ACE accounts — the CBP portal system companies use to access customs data and receive electronic refunds — are currently subject to a months-long backlog, a problem Santos says she warned clients about well before the portal launched.
Wood points to the disparity at play. “Bigger and more financially stable organizations will always have an advantage given their purchasing power and ability to invest in both process and technology infrastructure,” he says. “The IEEPA situation has done little to change that.”
