The tariffs came fast, the court orders came faster, and now the question for most importers who paid IEEPA duties is not whether they are entitled to a refund for a large number of entries, the legal question has been resolved, but whether they have done what is required to actually collect one. That is where CAPE comes in, and where Phase 2 changes the picture for a category of entries that had been left out of the initial framework.
Background: What CAPE Is and Why It Exists
IEEPA duties created an unusual problem for CBP. The agency processes a large but relatively manageable number of refunds in a normal year (about 338,000 in all of fiscal year 2025). The volume of entries for which IEEPA refunds were potentially owed was orders of magnitude larger. Processing those through normal protest and liquidation channels would have taken years and overwhelmed existing infrastructure.
CAPE, the Consolidated Administration and Processing of Entries tool, is CBP’s answer. Launched in Phase 1 on April 20, 2026, it is an electronic framework built into the ACE Secure Data Portal that allows importers and authorized customs brokers to submit IEEPA duty refund claims in bulk. Instead of filing entry by entry through the protest process, an importer submits a CSV file listing up to 9,999 entry numbers per declaration. ACE validates the entries, removes the applicable IEEPA HTS chapter 99 tariff lines, recalculates duties as if IEEPA had never applied, and processes the refund, including interest under 19 CFR 24.36, as a single consolidated ACH payment.
The scale of what has moved through Phase 1 alone is worth pausing on. As of mid-May, CBP reported that more than 15 million entries had passed CAPE file and entry-level validations. Estimated refund and interest amounts for liquidated and reliquidated entries ran to approximately $35.46 billion. In the first six weeks of operation, CAPE processed 8.5 million entries, compared to 338,000 total refunds CBP processed in all of fiscal year 2025. Whatever reservations anyone has about how the tariff situation was handled, the refund infrastructure is moving real money.
What Phase 1 Covered and What It Left Out
Phase 1 was deliberately scoped to handle the most straightforward entries first: unliquidated entries and entries within 80 days of liquidation that did not involve antidumping or countervailing duties, active protests, drawback claims, or reconciliation flags. The 80-day window is important. An entry that was liquidated more than 80 days before the CAPE declaration is filed is ineligible under the current framework.
That left a meaningful subset of entries in a holding pattern. Specifically, entries that were flagged for reconciliation, meaning they were tied to a subsequent reconciliation entry that would true up final duties after all relevant information was available could not be included in a CAPE declaration under Phase 1, regardless of their liquidation status.
What Phase 2 Changes
Phase 2, which went live on June 29, 2026, expands CAPE eligibility to cover entry types 01, 02, and 06 that are flagged for reconciliation, provided the reconciliation entry (type 09) has not yet been filed. The same eligibility window applies: entries must be unliquidated or within 80 days of liquidation.
The mechanics work like this. Once a reconciliation-flagged entry is accepted on a CAPE declaration, the CAPE process removes the IEEPA duties from the underlying entries before the reconciliation entry is filed. This is the key structural change: it separates the IEEPA duty refund calculation from the reconciliation calculation, so the two processes do not interfere with each other. After the reconciliation entry is filed, CBP will treat all associated CAPE declarations for those entries as having been properly filed and accepted.
The sequencing rule is critical and bears repeating. CBP’s guidance is explicit: if you have a reconciliation-flagged entry that is eligible for CAPE Phase 2, file the CAPE declaration before you file the reconciliation entry. Once a type 09 reconciliation entry is filed, the underlying entries become ineligible for CAPE processing in this phase. File in the wrong order and you close the door on the refund.
The one exception to that sequencing is timing pressure. If your reconciliation filing deadline is within 30 days, CBP says to prioritize the reconciliation entry over the CAPE declaration. A missed reconciliation deadline is a harder problem than a delayed CAPE filing. Do not let a refund opportunity cause you to blow a compliance deadline.
The Warehouse Entry Update
Effective July 8, 2026, one week after the launch of Phase 2, CBP made an additional change: warehouse entries, specifically entry types 21 and 22, are no longer accepted on CAPE declarations. Warehouse withdrawals, types 31, 32, 34, and 38, continue to be accepted, with refunds processed upon reliquidation of the associated withdrawal entry.
This creates a potential gap for a specific group of importers. If you had warehouse entries accepted on a CAPE declaration between April 20 and July 6 without a corresponding warehouse withdrawal submission, those entries will not be reliquidated with an IEEPA duty refund under the current framework. You will need to file a separate CAPE declaration covering the warehouse withdrawals on which IEEPA duties were paid. If this applies to your entry portfolio, the time to address it is now, not after your remaining entries age out of the eligibility window.
What Is Still Waiting on Future Phases
CAPE is not yet comprehensive. Several entry categories remain excluded from the current framework and are being addressed in future phases, with no firm public dates announced.
Entries flagged for reconciliation where the type 09 reconciliation entry is already on file are ineligible under Phase 2 and will be handled in a later phase. Entries subject to active protests require separate handling though CBP has noted that if a protest was filed solely for IEEPA refund purposes and the entry is within the 80-day window, the importer can withdraw the protest and file under CAPE for faster processing. Drawback entries and antidumping or countervailing duty entries also remain in a future-phase queue.
There is also the unresolved question of finally liquidated entries where the importer has not filed suit at the Court of International Trade. CBP’s current position is that it cannot issue refunds for those entries without a court order. That issue is on appeal at the Court of Appeals for the Federal Circuit under Case No. 26-1898. Until the appeal is resolved, CBP will not expand CAPE to cover that category. If you believe you have finally liquidated entries that may qualify, the filing deadline at the CIT is not a distant concern. One trade attorney has noted that importers should have their CIT complaints filed before the end of January 2027. Do not wait.
Fraud Warning
CBP has also flagged an increase in scam activity related to IEEPA refunds and CAPE processing, and it is worth passing along. Fraudulent actors are contacting importers and brokers posing as CBP representatives, requesting sensitive company and banking information in connection with refund processing. CBP has been clear: CAPE declarations are filed only through the ACE portal by the Importer of Record or the authorized customs broker who filed the original entries. CBP does not request Social Security numbers, bank account information, or passwords via email or text. Any communication requesting that information outside of ACE or official CBP channels should be treated as suspicious and reported to IEEPAFraud@cbp.dhs.gov.
A Practical Checklist
If you have not yet filed CAPE declarations for eligible entries, the process starts with an audit. Pull your entry portfolio and identify which entries fall into which category: straightforward unliquidated or recently liquidated entries that should have been handled under Phase 1, reconciliation-flagged entries now eligible under Phase 2, and entries that are still waiting on future phases. Confirm your ACE Secure Data Portal account is active and that your ACH banking information is properly enrolled. Refunds go out as ACH transfers, and CBP cannot release payment without confirmed account information. As of mid-May, more than 1,800 consolidated refunds were sitting unissued because ACH enrollment was missing.
Prepare your CSV files with entry numbers only, up to 9,999 per declaration, multiple declarations if needed, and submit through the CAPE tab in ACE. The IOR or the authorized broker who filed the original entries is the only party who can file the declaration. ACE will validate the submission and flag any entries that fail. Common rejection causes include entries outside the 80-day window, incorrect value reporting on IEEPA tariff lines, and HTS relationship or sequence mismatches.
Refunds are generally issued within 60 to 90 days of CAPE acceptance, depending on review and processing time. You can track status through the ACE Reports tools. The REV-615 CAPE Details Refunds Report is the most granular option for monitoring entry-level refund status.
The refund window is very real, and it is moving. The eligibility rules are specific enough that a missed deadline, a misordered filing, or missing ACH information can close the door on a recovery that may be substantial. Audit your portfolio, confirm your filing sequence, and get the declarations in.