Dear Valued Clients,
U.S. Customs and Border Protection (CBP) filed an important status update on March 31 regarding the development of its CAPE system for processing IEEPA tariff refunds. Below are the key takeaways for Phase 1:
System Development Progress (as of March 30, 2026)
- Claim Portal: 85% complete
- Mass Processing: 60% complete
- Refund Component: 75% complete
- Review & Liquidation/Reliquidation: 80% complete
What CAPE Phase 1 Covers
- Limited to entries that are unliquidated or within the 90-day voluntary reliquidation window
- Includes entries under suspended, extended, or under review status, as well as warehouse entries
- Refunds will generally be issued upon liquidation, not immediately
What Is Excluded in Phase 1
- Entries under reconciliation or drawback
- Entries with open protests
- Entries not filed in ACE or without a liquidation status
- Certain AD/CVD entries pending liquidation instructions
- Finally liquidated entries (to be addressed in a future phase)
Processing Timeline
- CBP expects up to 45 days to review and process accepted CAPE submissions
Key Considerations for Importers
- It remains unclear how protests will interact with CAPE eligibility
- Waiting to file protests may risk missing deadlines
- CBP will conduct compliance checks and may offset refunds
- Ensuring accurate documentation (classification, value, COO) is critical
CBP also indicated that future phases will expand functionality, including the ability to process finally liquidated entries.
We recommend reviewing your entries carefully and coordinating next steps based on your filing status and timelines.
We will continue to monitor developments and provide updates as more information becomes available.
If you have any questions or would like assistance reviewing your entries and eligibility, please contact our Licensed Customs Brokerage Team at pilar.dorfman@phoenixintlinc.com.\
Thank you!
