In CSMS # 69035485 (sent June 23, 2026) CBP published an update on the Consolidated Administration and Processing of Entries (CAPE) for IEEPA refunds. As of June 29, 2026, a new functionality will be available in CAPE that provides for the acceptance of entries flagged for reconciliation with no reconciliation entry on file.
Effective June 29, 2026, CAPE will accept entries flagged for reconciliation (entry types 01, 02, 06) for which the reconciliation entry (entry type 09) has not been filed. All filing and processing requirements from the first phase of CAPE remain in effect, and the entries flagged for reconciliation will be limited to unliquidated entries and entries within 80 days of liquidation as in CAPE Phase 1.
After the entries flagged for reconciliation are accepted on a CAPE declaration, the trade may file the reconciliation entry. The CAPE process removes the IEEPA duties from the flagged entries prior to the filing of the reconciliation entry, separating the IEEPA duty refund from the calculations on the reconciliation entry. Once the reconciliation entry is filed, CBP will assume that all the CAPE declarations associated with the reconciled entries were filed and accepted. After a reconciliation entry is filed, the underlying entries will not be eligible to be filed on a CAPE declaration in this phase.
Entries flagged for reconciliation and with a reconciliation entry already on file are not included in this phase of CAPE deployment. It is important to note that CAPE does not preclude filing a reconciliation entry for entries subject to reconciliation. Importers should prioritize filing the reconciliation entry for entries that are subject to reconciliation and with a reconciliation filing date less than 30 days in the future.
CBP advises that entries flagged for reconciliation with a reconciliation entry already on file will be included in a future phase of CAPE development.
For further information about this and other Customs matters, contact George Tuttle III at geo@tuttlelaw.com or 415-986-8780.
The information in this article is general in nature and is not intended to constitute legal advice or to create an attorney-client relationship with respect to any event or occurrence and may not be considered as such.
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