May 2026
Asia Agent Pte Ltd
On April 20, 2026, CBP launched CAPE — the Consolidated Administration and Processing of Entries system. It's the only way to claim back IEEPA tariffs that the Supreme Court ruled unlawful in February.
The numbers are real. $166 billion in IEEPA duties. 330,000 importers. 53 million entries. Your share of that is sitting in a government account right now, and you have to actively file to get it back. It doesn't come to you automatically.
Phase 1 covers roughly 63% of eligible entries — specifically unliquidated entries and entries within 80 days of liquidation. Refunds are expected within 60 to 90 days of accepted filing. The government has until June 7 to appeal. If they do, refunds could pause mid-stream.
File before June 7. That's the clock.
You need three things:
1. ACE Portal access. Either you as the Importer of Record, or the customs broker who originally filed your entries. Not your current broker. The broker who filed those specific entries. If that relationship has changed, you have a problem.
2. ACH refund banking enrolled in ACE. No bank enrollment, no refund. Full stop.
3. Your entry numbers. Pull the Entry Summary Details Report (ES-003) in ACE, filtered on HTSUS Chapter 99 provisions 9903.01.XX and 9903.02.XX. That gives you your IEEPA-exposed entries.
One warning: the CSV submission format is unforgiving. One formatting error rejects the entire declaration. In week one, 19% of entries that passed file validation were rejected at the entry level. File a small test batch first. Then go bulk.
This is your customs broker's job, not yours. If they haven't called you about this yet, call them.
You're getting money back. Maybe a little. Maybe a lot. Either way, you're about to have a conversation with yourself about where to manufacture next.
That's the conversation I want to have with you here. Not the tariff rate conversation. That changes every 90 days. I want to talk about the factory floor reality.
Because I've seen too many brands move their supply chain based on a tariff number — without understanding what they're actually moving into.
Vietnam is real. The growth is real. For the right product, it works.
But here's what the tariff calculator doesn't tell you.
Vietnamese factories — particularly in the north — are running at capacity. Foxconn, Apple, Samsung, BYD. They've been hiring at scale since 2023. When you show up as a brand doing 5,000 units, you're competing with those buyers for factory time, skilled operators, and raw material allocation.
Most factories in Vietnam that will take your order are either:
Neither is automatically wrong. But you need eyes on the factory before you commit. Not a factory audit report from a third party. Someone on the ground, in the relationship, who knows what a real Vietnam operation looks like versus a Chinese assembly line with a Vietnamese flag out front.
The US-China tariff truce runs through November 2026. Effective tariff rate on Chinese goods is around 30% — high, but Section 301 has been at 25% since 2018 and people have been manufacturing in China the entire time.
What's different now isn't the tariff. It's the relationship. Chinese factories that have been moving capacity to Vietnam, India, and Indonesia for the past two years are not fully committed to their China lines anymore. MOQs have shifted. Lead times have stretched. Subcontracting without notice has become more common, because factory owners are spreading production across multiple hubs.
Your China factory relationship needs active management right now. Not emails. On-site presence. Factory visits. Payment structure reviews. If you're managing your China supplier from a laptop in Los Angeles or London, you're running on old information.
India is real for certain categories: apparel, leather goods, home textiles, some electronics assembly. The government is actively courting foreign manufacturing investment. But infrastructure is inconsistent, factory management practices vary enormously between regions, and lead times are longer than China at equivalent volume.
Indonesia is strong in furniture, footwear, some apparel. Factory relationships here take longer to build but tend to be more stable once established. Jakarta-area factories are increasingly sophisticated. Outer island production is cheaper but harder to supervise.
Both markets require someone on the ground. You cannot manage Indian or Indonesian factories at arm's length any more than you can manage Chinese ones.
Before you redirect your IEEPA refund into a factory relocation, ask yourself these questions:
1. Do I have a verified factory relationship in the new hub, or am I responding to a trade show introduction? There's a difference between a factory that can produce your product and a factory that will produce your product correctly, consistently, at your price point, without subcontracting it out the back door.
2. Can I verify substantial transformation in Vietnam — not just assembly? If your product has China-origin components above 60-70% of value, you have a transshipment exposure problem that no amount of Vietnam invoicing will fix when CBP looks at your supply chain.
3. Do I have infrastructure on the ground in the new hub? Language. Culture. Legal framework. Payment structure. Inspection process. These are not details. They're the operating system. You need someone who speaks the language and knows the factories personally.
4. Am I moving for the right reason? Moving supply chain to save 10% on tariffs, while adding 15% in transition costs, higher defect rates, longer lead times, and weaker supplier relationships — is not a win. Run the full landed cost model, not just the duty rate.
Asia Agent puts boots-on-the-ground support across China, Vietnam, India, and Indonesia. We connect you directly to real factories — not trading companies, not middlemen. We manage the language, the culture, the legal differences, and the factory relationship on your behalf.
Our rule is simple: No inspection, no load. No customs readiness, no ETD.
If you're weighing where to manufacture next — or you're getting your IEEPA refund and thinking about what to do with it — we can walk you through what each hub actually looks like for your product category.
No fluff. No sales pitch. Just ground truth.
What is CAPE and how do I file for my IEEPA refund? CAPE (Consolidated Administration and Processing of Entries) is CBP's electronic refund system, live since April 20, 2026. You or your customs broker files a CAPE Declaration through the ACE Portal. Only the original Importer of Record or the broker who filed those specific entries can submit. You'll need your entry numbers, an ACE account, and ACH banking enrolled. Refunds are expected within 60 to 90 days of accepted filing.
What is the deadline to file for IEEPA refunds? There is no published hard deadline for Phase 1 filing, but the government has until June 7, 2026 to appeal the refund order. If an appeal is filed and a stay granted, refunds could pause. Entries also age out of Phase 1 eligibility as they move past the 80-day liquidation window. File as early as possible.
Which entries qualify for Phase 1 CAPE refunds? Phase 1 covers unliquidated entries and entries within 80 days of liquidation that had IEEPA-specific HTSUS Chapter 99 codes declared. Entries with AD/CVD flags, reconciliation entries, and entries liquidated more than 90 days ago are excluded from Phase 1 and will be handled in later phases.
Should I move my supply chain from China to Vietnam because of tariffs? Not automatically. Vietnam works well for certain product categories, but factories are running at capacity, and Chinese-owned assembly operations moving final steps across the border carry transshipment exposure under CBP's 40% transshipment tariff. The right decision depends on your product, your volume, your timeline, and whether you have verified factory relationships in the new hub.
Can I manufacture in Vietnam using Chinese components and still claim Vietnam origin? Possibly, but it depends on substantial transformation — not just where final assembly happens. CBP looks at value-add, the manufacturing process, and whether the product code changes. If Chinese-origin components represent 60-70% or more of the value, you need to assess your exposure carefully before making origin claims.
What's the difference between a real Vietnam factory and a transshipment operation? A legitimate Vietnam operation generates meaningful local value — skilled labor, local material inputs, actual manufacturing steps that transform the product. A transshipment operation imports mostly-finished Chinese goods, performs minimal assembly, and ships with a Vietnam label. CBP tracks shipment-level customs data and can identify patterns. On-site verification is the only way to know for certain what you're dealing with.
How does Asia Agent help with manufacturing hub decisions? We provide on-the-ground factory verification and relationship management across China, Vietnam, India, and Indonesia. We connect clients directly to factories — no middlemen, no trading companies. We verify production capacity, CoO documentation practices, and supply chain integrity before any production commitment is made.