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An Update on the Evolution of the CAPE System for IEEPA Duty Refunds
Transitioning to the CAPE System for IEEPA Duty Refunds 1. Strategic Overview of the CAPE Rollout U.S. Customs and Border Protection (CBP) is currently executing a high-stakes transition from manual processing of International Emergency Economic Powers Act (IEEPA) duty claims to the Consolidated Administration and Processing of Entries (CAPE) system. This evolution is a critical modernization of the Automated Commercial Environment (ACE), designed to manage the calculation an
GRF Customs
Apr 25 min read


CIT Update: Mandatory Reliquidation Ordered for All IEEPA Entries—Including Final Liquidations
Following recent court orders, there is significant news regarding the reliquidation of entries entered subject to IEEPA duties. The U.S. Court of International Trade has directed that any unliquidated entries, as well as liquidated entries for which liquidation is not yet final, be reliquidated without these duties. Notably, on March 27th, 2026, the court has further ruled that even liquidated entries for which liquidation is final shall be reliquidated without regard to IE
GRF Customs
Mar 301 min read


Technical Advisory: Evolution of the CAPE System and Automated IEEPA Duty Refunds as of March 19th, 2026
1. Strategic Context of IEEPA Duty Refund Automation The development of the Consolidated Administration and Processing of Entries (CAPE) system represents a pivotal advancement in the functional capabilities of the Automated Commercial Environment (ACE). Within the broader ACE framework, CBP is leveraging CAPE to mitigate fiscal leakage and ensure regulatory consistency across the system of record by shifting toward automated revenue protection and the streamlined processing
GRF Customs
Mar 204 min read


Code vs. Cash: Inside CBP’s Scramble to Automate the Largest Trade Refund in History
In the matter of Atmus Filtration, Inc. v. United States (Case 1:26-cv-01259-RKE), the U.S. Court of International Trade (CIT) and U.S. Customs and Border Protection (CBP) have reached a critical phase regarding the refund of tariffs following a Supreme Court ruling. The following updates are based on the latest filings from the CIT docket and official declarations from CBP leadership as of March 14, 2026 . Current Status: Refund Mandate & Implementation Following the Suprem
GRF Customs
Mar 142 min read


The Securing Accountability in Foreign Entries (SAFE) Act
Illustration of the iconic American Capitol dome and simple ring of American flag stars The Securing Accountability in Foreign Entries Act: A Strategic Analysis of Proposed Reforms to U.S. Import Laws 1. Legislative Overview and the Push for Domestic Accountability The introduction of the "Securing Accountability in Foreign Entries Act" (S. ll) represents a paradigm shift in U.S. trade enforcement and supply chain liability. By proposing foundational amendments to Section 484
GRF Customs
Mar 105 min read


The 0.2% Crisis: Constitutional Stakes and the Resurrection of Fixed-Rate Trade Law, Section 122
The Pivot from IEEPA to the "Zombie" Statute, Section 122 On February 20, 2026, the United States Supreme Court delivered a finality that many assumed would terminate the era of unilateral executive trade wars. In Learning Resources, Inc. v. Trump , the Court ruled that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose broad global tariffs. Yet, before the ink on the decision was dry, the Executive Branch performed a maneuver o
GRF Customs
Mar 65 min read


The End of IEEPA Tariffs
This presentation, provided by GRF Customs Broker , outlines the significant trade policy shift following the Presidential Order signed February 20, 2026 , which immediately repealed nine key IEEPA tariff actions affecting imports from Canada, Mexico, China, Russia, Iran, Brazil, Venezuela, and Cuba . While these specific ad valorem duties are being terminated "as soon as practicable," the underlying National Emergencies remain in effect, and restrictions such as Section 2
GRF Customs
Feb 231 min read


Electronic Refunds Interim Final Rule Effective February 6, 2026
Executive Order (E.O.) #14247, Modernizing Payments To and From America’s Bank Account was issued on March 25, 2025. The E.O. mandates that the U.S. Treasury no longer issues paper checks. In accordance with Executive Order #14247, CBP will transition from issuing paper refund checks to utilizing the Automated Clearing House (ACH) system to issue refunds via Electronic Funds Transfer (EFT).
GRF Customs
Feb 72 min read
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