New CAPE capabilities enable earlier refund processing for reconciliation-flagged entries.

U.S. Customs and Border Protection (CBP) has issued updated guidance expanding the capabilities of the Consolidated Administration and Processing of Entries (CAPE) tool within the Automated Commercial Environment (ACE). Effective June 29, 2026, importers may submit certain entries flagged for reconciliation through CAPE—even where the reconciliation entry has not yet been filed—providing greater flexibility in pursuing refunds of duties imposed under the International Emergency Economic Powers Act (IEEPA). 

Background

CAPE was launched on April 20, 2026, to facilitate the processing of IEEPA duty refunds. This latest update represents a significant enhancement to initial functionality by allowing participation for entries flagged for reconciliation earlier in the entry lifecycle. 

Key Regulatory Development

CBP will now permit the submission of CAPE declarations for entry types 01, 02, and 06 that are flagged for reconciliation, even where the reconciliation entry (type 09) has not yet been filed. This functionality applies only to unliquidated entries and entries that are within 80 days of liquidation. 

Operational Impact

The updated CAPE process allows for the removal of IEEPA duties from underlying entries prior to reconciliation filing, effectively separating the refund process from reconciliation calculations. Once a reconciliation entry is filed, CBP will treat associated CAPE declarations as properly submitted and accepted. 

Limitations and Constraints

Entries for which a reconciliation entry has already been filed are not included in this phase. Importers with reconciliation deadlines approaching should prioritize filing reconciliation entries to avoid compliance risk. Entries already reconciled will not be eligible for CAPE processing in this phase.

Strategic Considerations

Importers should evaluate flagged entries to determine eligibility within the 80-day window, assess timing between CAPE submissions and reconciliation obligations, and coordinate with brokers and advisors to ensure proper sequencing and compliance.

Next Steps

Trade stakeholders should review their entry portfolios immediately to determine eligibility and prepare for the June 29, 2026 effective date.

Disclaimer

This advisory is provided for informational purposes only and does not constitute legal advice. Importers should consult with trade counsel or compliance professionals to assess applicability to their specific facts and circumstances.