CBP Expands CAPE Eligibility for Certain Reconciliation-Flagged Entries (Effective June 29, 2026)
CBP has expanded the Consolidated Administration and Processing of Entries (CAPE) process for IEEPA duty refunds.
Effective June 29, 2026, CAPE will now accept certain entries flagged for Reconciliation (entry types 01, 02, and 06) when a Reconciliation Entry (Type 09) has not yet been filed. Eligible entries remain limited to those that are unliquidated or within 80 days of liquidation.
Once accepted into CAPE, CBP will remove the IEEPA duties from the underlying entry before the Reconciliation Entry is filed, separating the refund process from subsequent Reconciliation calculations.
Entries with a Reconciliation Entry already on file are not included in this phase and will be addressed in a future CAPE enhancement.
Who Is Impacted?
This update impacts importers seeking IEEPA duty refunds on entries flagged for Reconciliation where:
No Reconciliation Entry (Type 09) has been filed;
The entry remains unliquidated; or
The entry is within 80 days of liquidation.
Entries with a Reconciliation Entry already on file remain ineligible under the current CAPE deployment.
Risk of Non-Compliance
Failure to identify eligible entries before filing a Reconciliation Entry may result in the loss of refund opportunities available through the current CAPE phase.
Additionally, if Reconciliation deadlines are approaching, those filings should not be delayed while waiting for CAPE-related action.
Janel's / Broker's Ability to Help
If we identify a client with eligible Reconciliation-flagged entries for which a CAPE declaration may be appropriate, we must do the following before we can file:
Discuss billing and refund options.
Obtain the Importer of Record's (IOR's) written authorization to file.
Ongoing Developments
CBP continues to expand CAPE functionality, and additional phases are expected. Industry sources have indicated that a future CAPE phase may address certain entries that are currently outside CAPE eligibility, including some entries liquidated beyond the current 80-day window; however, CBP has not formally announced a deployment date or filing requirements.
At the same time, the broader IEEPA refund landscape remains subject to ongoing litigation. According to recent updates from NCBFAA Customs Counsel and Legislative Advisor, Sandler, Travis & Rosenberg (ST&R), uncertainty remains regarding the availability and timing of refunds for certain liquidated entries, as legal challenges and government positions on refund authority continue to be addressed through the courts.
CBP has stated that additional CAPE enhancements and guidance will be announced through future CSMS messages. Janel will continue to monitor developments and provide updates as additional information becomes available.
For assistance and additional questions, please reach out to Janel Group's Compliance Team or a Janel Group Representative.
Director of Trade Compliance
Senior Compliance Analyst