🇺🇸 USFBA FeesMedium ImpactJune 29, 2026
CAPE Phase 2 Is Live: IEEPA Duty Refunds Open Up to Reconciliation-Flagged Entries, While Phase 3 for Liquidated Entries Still Has No Launch Date
Effective: June 29, 2026
US FBA and FBM sellers who imported inventory subject to IEEPA tariffs and whose entries were flagged for reconciliation without a reconciliation entry yet on file, provided those entries are still unliquidated or within 80 days of liquidation. Sellers whose entries have finally liquidated, are drawback-designated, sit under an open protest, or were not filed in ACE are still outside CAPE and have no scheduled path in.
CBP deployed Phase 2 of the Consolidated Administration and Processing of Entries (CAPE) system in the ACE Portal on June 29, 2026, extending the IEEPA duty refund process to entries that were flagged for reconciliation but do not yet have a reconciliation entry on file. Filing works exactly as it did in Phase 1 — CAPE Declarations submitted as CSV files through ACE — and the same timing limits apply: only unliquidated entries and entries within 80 days of liquidation qualify. Everything else importers were waiting on, including finally liquidated entries, drawback-designated entries, warehouse entries, entries under open protest, and AD/CVD entries, remains parked in a future phase that CBP has not scheduled.
Key Points
- CAPE Phase 2 was deployed in the ACE Portal on June 29, 2026, expanding who can file an IEEPA duty refund claim
- Phase 2 covers entries flagged for reconciliation where the corresponding reconciliation entry is not yet on file — consumption entry types 01, 02, and 06 without a type 09 reconciliation entry filed
- The Phase 1 timing limits carry over unchanged: only unliquidated entries and entries within 80 days of liquidation are eligible, so Phase 2 widens the entry types, not the clock
- Filing requirements and processing procedures are identical to Phase 1 — CAPE Declarations submitted as CSV files through the ACE Portal by the importer of record or their broker
- CBP is still evaluating later phases for entries with a reconciliation summary already filed, drawback-designated entries, warehouse entries, entries under open protest, entries not filed in ACE, AD/CVD entries, and finally liquidated entries — no launch date has been announced for any of them
- The government continues to contest whether refunds are owed at all on finally liquidated entries, so building the Phase 3 capability would not by itself settle whether those refunds are paid
What You Should Do Now
- 1Ask your customs broker to pull which of your IEEPA entries are flagged for reconciliation and whether a type 09 reconciliation entry has already been filed against them — only the ones without a filed reconciliation entry are in Phase 2 scope
- 2Check the liquidation status on those entries before anything else: entries that have liquidated more than 80 days ago fall out of scope regardless of reconciliation flags
- 3If entries qualify, have your broker add them to a CAPE Declaration CSV in ACE using the same process as Phase 1 — there is no separate Phase 2 filing workflow to learn
- 4For entries that are already finally liquidated or otherwise outside scope, keep the duty documentation intact and preserve your protest and litigation options rather than waiting on a Phase 3 date that CBP has not given
- 5Re-check CBP's IEEPA duty refunds page periodically — CBP has said further communications will be issued as additional capabilities are developed
Official Source
U.S. Customs and Border Protection →This summary is written in our own words based on the official source linked above. Policies may be updated after publication. Always check the official Amazon source for the latest details.