CBP Publishes CAPE Phase 1 Update

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Apr. 14, 2026
By: Pietro N. Bianchi

CBP published CSMS #68340863, which provides further details for Phase 1 of its multiple-entry IEEPA refund claims system: Consolidated Administration and Processing of Entries (“CAPE”). CBP stated that CAPE is on track to deploy 8:00 AM EDT on April 20, 2026 and reminded importers to set up electronic refunds via Automated Clearing House in ACE.

CBP announced that CAPE will remove the Chapter 99 IEEPA HTS numbers at the entry summary line level and recalculated duties owed as if IEEPA duties were never owed. The refund will be the difference between the original and recalculated entry with any interest owed. CBP will check for any unpaid debts and subtract the amount from the refund total before issuance. Refunds will be consolidated by importer or designated 4811 party and liquidation date before dispersed as a lump sum.

Unliquidated entries where liquidation is not extended, suspended, or under review will be set to liquidate 45 days from acceptance of the CAPE Declaration and refunds will be issued 15-45 days after liquidation.

Entries with liquidation extended, suspended, or “under review” will maintain their liquidation status and any refunds will be issued upon liquidation.

Warehouse entries will be processed in the normal course after all withdrawals have been made and the entry is ready for liquidation. CBP will process any refunds upon liquidation. 

Liquidated entry summaries will reliquidate the business day after the CAPE declaration; CBP has not indicated when refunds would be processed.

Reconciliation, drawback, USMCA deferred duty, temporary importation under bond, and AD/CVD entries will not be accepted during Phase 1. Further, entries with an open or suspended protest and entries over 80 days past the liquidation date will not be accepted during Phase 1.

CBP states that protest submitted solely for IEEPA refund on entry summary within 80 days of the liquidation date may be withdrawn for faster refund processing. However, this should be done with careful consideration. Should a problem arise with the refund process or the government appeal implementation of the refunds, Importers may lose their claim to refunds.

If you have questions about IEEPA refunds do not hesitate to contact an attorney at Barnes Richardson, & Colburn LLP.