When CAPE Opened This Morning, Not Every Walmart Supplier Was Eligible to File

At 8 a.m. Eastern this morning, U.S. Customs and Border Protection launched the first phase of the Consolidated Administration and Processing of Entries tool, or CAPE, inside the ACE Secure Data Portal. The launch follows the Supreme Court’s 6-3 ruling on February 20 in Learning Resources, Inc. v. Trump, which held that the International Emergency Economic Powers Act does not authorize the president to impose tariffs. CBP’s guidance confirms Phase 1 covers unliquidated entries and entries within 80 days of liquidation, with refunds generally issued 60 to 90 days after a CAPE Declaration is accepted.

According to CBP, as of April 14, 56,497 importers had completed ACH registration, a prerequisite for receiving refunds, and were eligible for a combined $127 billion including interest. Up to 82% of IEEPA duty payments are eligible for refunds in CAPE’s initial deployment.

Those figures matter less to a Walmart supplier than one smaller question: were you the importer of record?

The Answer Is Written Into Your Walmart Relationship, Not Your Contract

Walmart’s own U.S. Product Quality and Compliance Manual draws the line explicitly. “Domestic Import: Supplier is the importer of record. Direct Import: Walmart is the importer of record.” That single distinction determines whether a supplier can file a CAPE Declaration, or whether the refund, if any, flows through Walmart’s own import operations.

CBP’s guidance is unambiguous on this point. Only the importer of record, or the licensed customs broker who filed the entries on the IOR’s behalf, can file a CAPE Declaration. Consumers and downstream parties who absorbed higher costs through the supply chain are not eligible. A supplier who sold finished goods to Walmart on a domestic basis, even if those goods originated overseas, has no standing to file if Walmart was the IOR on the inbound entry.

Direct Import Suppliers Have No Claim to File

When Walmart is the importer of record on goods sourced from a supplier’s overseas facility, Walmart paid the IEEPA duties and Walmart is the party entitled to claim the refund. The supplier, even the one that made the product, is not eligible to submit a CAPE Declaration on those entries. For suppliers in this arrangement, the question is whether IEEPA-era cost pressure was passed along through cost negotiations, markdowns, or margin concessions, and whether any of that is worth revisiting in upcoming line reviews or Joint Business Planning conversations. Nothing in the CAPE process creates a direct path for that.

Domestic Import Suppliers Are Eligible, and the Clock Is Tight

Suppliers who import their own goods into the United States and then sell them domestically to Walmart were the importer of record on those entries. They paid the IEEPA duty directly to CBP. They are the ones who can file.

The mechanics are straightforward but unforgiving. A CAPE Declaration is a CSV file uploaded through the CAPE tab in the ACE Portal, containing only entry numbers, with a cap of 9,999 entries per declaration. Before filing, the IOR needs an active ACE Portal account with Importer sub-account access and ACH banking information on file, since all refunds are issued electronically. According to CBP guidance, refunds will generally be issued within 60 to 90 days following acceptance of a CAPE Declaration.

Phase 1 limits are where many suppliers will get tripped up. CAPE covers unliquidated entries and entries liquidated within the preceding 80 days. Entries liquidated more than 80 days ago, and entries under protest, are excluded from this phase. Flexport president Sanne Manders told CBS News that Phase 1 eligibility covers roughly 63% of IEEPA entries, with the remaining 37% excluded from the initial rollout. CBP has said future phases will address more complex scenarios, but has not published a timeline.

For a domestic-import Walmart supplier whose IEEPA exposure stretches back through the IEEPA collection period, a meaningful portion of eligible duty may already sit outside the 80-day window. The practical step for finance teams is to have a customs broker pull the full list of IEEPA entries, segment by liquidation date, and file the Phase 1-eligible entries as a clean declaration before the next wave of liquidations pushes additional entries out of reach.

Marketplace Sellers Need to Check Their Cross Border Enrollment

For 3P sellers using Walmart Marketplace and Walmart Fulfillment Services, the importer of record question is answered inside Seller Center. Walmart’s Cross Border: Imports enrollment guide requires sellers to provide “Importer of record (IOR) company and contact information” and the “IOR’s US Customs continuous bond number,” with the option to designate either their own IOR or use a third-party IOR.

A seller who enrolled as their own IOR, or who used their own entity as the IOR, is the party eligible to file under CAPE. A seller who used a third-party IOR will need to confirm with that party whether the refund claim is being filed on the seller’s behalf, whether the refund will be passed through, and on what terms. Sellers who import outside Cross Border: Imports entirely are in the same position as any other direct importer and should be working with their customs broker now.

The segmentation matters because of how Marketplace is structured. Walmart’s own policy documentation identifies the Marketplace Seller as the seller of record for all purposes other than marketplace facilitator tax collection. That principle extends to the tariff question: for Marketplace inventory where the seller was IOR, the seller owns the refund process end to end.

The Refund Doesn’t Solve Today’s Cost Problem

Every Walmart supplier category faces one further constraint. On February 24, 2026, the administration replaced the invalidated IEEPA tariffs with a 10% ad valorem surcharge under Section 122 of the Trade Act of 1974, effective for 150 days through approximately July 24, 2026. CBP stopped collecting IEEPA duties at 12:00 a.m. EST on February 24 and began collecting the Section 122 surcharge at 12:01 a.m. the same day. Section 122 duties are not refundable through CAPE and are not affected by the Supreme Court’s ruling. Section 232 tariffs on steel, aluminum, autos, copper, semiconductors, and lumber also remain in effect, as do Section 301 tariffs on Chinese imports.

For suppliers modeling cost, the refund claim addresses a discrete window of IEEPA collection ending February 20, 2026, and does not reduce ongoing landed cost. On Walmart’s Q4 FY26 earnings call in February, CFO John David Rainey told analysts that inflation at Walmart U.S. in the quarter was “just above 1%” and said the retail industry had “largely” absorbed the brunt of earlier tariff impacts. The Section 122 surcharge, which took effect days after that call, is a forward-looking cost item that the CAPE process does not touch.

What This Changes Going Into the Next Line Review

The CAPE rollout arrives at an awkward moment. Cost negotiations, JBP updates, and replenishment plans over the last twelve months reflected a duty environment that no longer exists, while the replacement duty environment is both newer and has a statutory July expiration. Suppliers who imported their own goods and are now receiving, or soon expecting, IEEPA refunds will need to decide how to reflect that recovery in cost conversations already on the calendar. Suppliers who did not import, and therefore have no refund to claim, should expect the question to come up from the other side of the table. The IOR answer takes an afternoon with a customs broker. Knowing what to do with that answer is the harder part.

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