CBP Updates CAPE Guidance for Entries Flagged for Reconciliation

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May 26, 2026
By: Marvin E. McPherson

CBP updated its guidance regarding entries flagged for reconciliation. Specifically, the guidance covers entry types 01, 02, and 06 that are (1) unliquidated or within the 80 day post-liquidation window, (2) flagged for reconciliation, and (3) have not yet been included on a type 09 reconciliation entry.

The guidance indicates that importers should hold off on Entry Type 09 reconciliation filings unless the reconciliation deadline is close to expiring, meaning less than 30 days remain. Instead, CAPE filings should be made for the entries. This sequencing will allow the CAPE declaration to be filed and processed before the 09 entry is filed.

CBP’s FAQ also states that if the CAPE capabilities are not up and running when the reconciliation entry must be filed, imports should file the reconciliation entry and deposit the duties, taxes, and fees owed without the increased IEEPA duties.

There are several entry categories that CAPE still is yet to accept, including:

• Entries designated on a drawback claim;
• Entries covered by an open protest;
• Entries not filed in ACE, and entries without a liquidation status in ACE;
• AD/CVD entries for which the Department of Commerce has issued liquidation instructions and that are pending liquidation under 19 U.S.C. § 1504(d); and
• Entries for which liquidation occurred more than 80 days prior.

The guidance also indicates that CBP is developing separate functionality for entries where the type 09 reconciliation entry is already on file. However, there is no actionable guidance on these entries yet.

While CBP continues to develop capabilities in CAPE, importers need to be more conscious than ever of the importance of tracking all entries subject to IEEPA duties to ensure that those entries are protected. In the meantime, e will continue to follow the refund procedures and case status. If you have any questions regarding the best course of action for your company, Contact any attorney  at Barnes, Richardson & Colburn, LLP.