Only liquidated entries and entries within the 90-day voluntary reliquidation period will be processed in Phase 1

To comply with the Court of International Trade’s amended order dated March 20, 2026, CBP revised the development scope of CAPE Phase 1 to limit processing to entries that are either unliquidated or within the 90‑day voluntary reliquidation period under 19 U.S.C. § 1501.

To meet the Phase 1 deployment timeline, CBP will continue development without including the finally liquidated entries.

CAPE Phase 1 will accept entries where the liquidation status is “Suspended,” “Extended,” or “Under Review,” as well as warehouse and warehouse withdrawal entries, but in these instances, refunds will be provided in the normal course upon liquidation, rather than immediately. This includes entries subject to AD/CVD.

CAPE Phase 1 Scope and Limitations

1. Eligible Entries
   • CAPE Phase 1 will process only:
     • Unliquidated entries; and
     • Entries within the 90‑day voluntary reliquidation period under 19 U.S.C. § 1501.
2. Entries with Suspended, Extended, or Reviewed Liquidation Status
   • Phase 1 will now accept CAPE Declarations containing entries whose liquidation status is suspended, extended, or under review.
   • CAPE will not liquidate or process refunds of IEEPA duties for these entries. The entries will be liquidated (without IEEPA duties) through normal CBP processes, and IEEPA duties will be refunded upon liquidation.
   • Entries subject to antidumping and/or countervailing duties (AD/CVD) are included if liquidation is suspended pending instructions from the U.S. Department of Commerce (DOC).
     • CBP will not liquidate or process IEEPA duty refunds until DOC issues instructions lifting the suspension and authorizing liquidation.
3. Warehouse Entries
   • CAPE Phase 1 will also accept CAPE Declarations containing:
     • Warehouse entries and warehouse withdrawal entries.
     • Liquidation of warehouse entries will continue through CBP’s normal processes after all withdrawals have occurred and the entry is ready for liquidation, at which time CBP will process the refund of IEEPA duties.

Entries Not Accepted in CAPE Phase 1

The following categories of entries subject to IEEPA duties will not be accepted on a CAPE Declaration in Phase 1:

• Entries flagged for reconciliation, including Entry Type 09 – Reconciliation Summary;
• Entries designated on a drawback claim;
• Entries covered by an open protest;
• Entries not filed in ACE, or entries without a liquidation status in ACE; and
• Entries subject to AD/CVD for which DOC has issued liquidation instructions and that are pending liquidation under 19 U.S.C. § 1504(d).

Processing Timeframes

• CBP will take up to 45 days from acceptance of a CAPE Declaration to review and liquidate validated entry summaries, unless a compliance concern requires further review.
• CAPE Phase 1 will accept Declarations containing entries liquidated within the preceding 80 days, ensuring that reliquidation can be completed by the 90th day, consistent with 19 U.S.C. § 1501.

Refund Processing and Electronic Payments

• CBP continues to evaluate more complex refund scenarios to determine which additional CAPE capabilities are required.
• CBP systems allow refunds to be issued to:
  • The importer of record (IOR); or
  • A party designated by the IOR via CBP Form 4811.
• Effective February 6, 2026, CBP issues all refunds electronically, as required by Executive Order 14247.
• As of March 26, 2026, 26,664 IORs have completed electronic refund enrollment.
  • These IORs filed 78% of all entries for which IEEPA duties and/or duty deposits were paid.
• Importers expecting refunds should ensure they are properly enrolled to receive ACH electronic refunds.

Planned CAPE Enhancements (Future Phases)

In subsequent phases, CBP expects to develop the following functionalities:

• Enhanced tools and validations to ensure compliance, facilitate entry summary processing, and expedite CBP review;
• Enhanced financial reporting and security tools;
• Tools to streamline revenue enforcement when outstanding bills for non‑IEEPA duties exist for entries on a CAPE Declaration;
• Capability to process entries flagged for reconciliation and entries designated on drawback claims, which present an increased risk of over‑refunding duties;
• Capability to process complex interest calculations involving multiple collection dates on a single entry summary;
• Capability to process finally liquidated entries; and
• Capability to process non‑Automated Broker Interface (ABI) entries where no entry summary lines exist.

Deringer Customers: Get Started with Electronic Refunds Here

To let us know how we may best assist you, please complete our client form for IEEPA protests and electronic refunds. Go to the Form

Due to the rapidly changing application and modifications of duty rates, please note that Deringer is not responsible for coordinating the timing of U.S. entry and imposed tariff rates.