The United States is entering a new phase of its tariff policy following a series of judicial decisions, immediate response measures, and the activation of an administrative refund system that will shape the coming months of 2026.
End of IEEPA tariffs following Supreme Court ruling
On February 20, 2026, the U.S. Supreme Court struck down the tariffs imposed under IEEPA authority, marking a structural shift in the existing tariff framework.
As a direct consequence, on February 24, 2026, U.S. Customs and Border Protection (CBP) stopped applying these duties. However, tariffs established under Sections §232 and §301 remain fully in force, maintaining part of the regulatory impact on international trade.
Immediate response: new 15% global tariff
In response to this regulatory gap, between February 20 and 21, 2026, the United States introduced a new 15% global tariff under Section 122.
This new duty is temporary, with a maximum duration of 150 days, setting its expected expiration date on July 24, 2026. However, there is uncertainty regarding a possible extension or its reintroduction in new regulatory forms.
New CAPE-CBP tariff refund system
One of the most relevant elements of the new landscape is the launch of CAPE (Consolidated Administration and Processing of Entries), managed by CBP, scheduled for April 20, 2026 within the ACE portal environment.
This system will allow companies to request refunds of tariffs previously applied under the IEEPA regime.
Operational process and requirements
To access the CAPE system, companies must meet several prerequisites:
- Have an active account in the ACE portal
- Have banking details (ACH) registered for transfers
From April 20, 2026, it will be possible to submit the “CAPE Declaration,” initiating the CBP review process.
The procedure will include:
- Removal of applied IEEPA tariffs
- Recalculation and administrative re-liquidation of entries (no fixed deadline)
- Issuance of consolidated refunds with interest
The estimated refund timeline is not fixed but is currently projected at around 12 to 18 months.
Limited temporal scope of CAPE
Phase 1 of the CAPE system will be limited to:
- Unliquidated entries, or
- Entries made within approximately 80 days from liquidation
- Transactions outside this window may require alternative routes, potentially of a litigation nature.
Implications for companies: a limited tactical window
This new scenario opens a very specific window of action for economic operators:
Now (Q2 2026):
- Preparation of ACE accounts and banking details
- Identification of affected 2025 operations
April – July 2026:
- Submission of CAPE claims
- Use of the reduced 15% tariff
After July 2026:
- Uncertain scenario:
- Possible end of the 15% tariff
- Potential new measures under §232 or §301
- Reconfiguration of the tariff framework
Conclusion: a critical 3 to 6-month period
The timeline defined by the end of IEEPA tariffs, the activation of the CAPE system, and the temporary validity of the new 15% tariff creates a particularly sensitive period for logistics and customs planning.
Companies have a limited tactical window of three to six months to optimize costs, manage refunds, and prepare for scenarios in a highly uncertain regulatory environment from the second half of 2026 onward.
