PHASE 2: CBP Now Accepting Reconciliation Entries in CAPE

Jun. 30, 2026
By: Hannah B. Kreinik

As a follow-up to our last article on Reconciliation entries, CBP has now officially deployed Phase 2 in the CAPE system, covering entries flagged for reconciliation. The newest phase in CAPE will accept entries flagged for reconciliation (entry types 01, 02, 06) for which the reconciliation entry (entry type 09) has not been filed. The CAPE process for reconciliation is still limited to unliquidated entries or entries liquidated within 80 days.

CBP’s CSMS instructions (here and here) state that the new phase is now live in the CAPE system and open to importers or brokers wishing to file flagged entries. In addition, importers and brokers should be aware that flagged entries filed in CAPE should be accepted prior to filing the entry for reconciliation. The CAPE process will remove the IEEPA duties from the flagged entries prior to the entry being reconciled with the appropriate duties. The instructions make clear that any filed reconciliation entries were already filed and accepted in CAPE and will no longer be eligible for a refund via the CAPE system.

The CSMS instructions also note that flagged entries with reconciliation already filed are not included in Phase 2. The instructions state that there will be another CAPE phase in the future that will cover these entries. The instructions also explain that flagged entries within 30 days of the reconciliation deadline should be filed and take precedence over CAPE filings.

Barnes, Richardson & Colburn attorneys are here to keep the trade informed on any CAPE phase developments and refund support.