US Customs and Border Protection has moved the IEEPA tariff refund process into Phase 2 June 29th, 2026, expanding CAPE beyond the first group of eligible entries and opening the system to certain reconciliation-flagged entries. CBP’s IEEPA Duty Refunds portal identifies CAPE as the agency’s ACE-based system for streamlining valid refund requests for duties imposed under the International Emergency Economic Powers Act.
CAPE, short for Consolidated Administration and Processing of Entries, allows importers and brokers to submit refund requests electronically through the ACE Portal. CBP’s June 2026 CAPE Declarations and Error Definitions guide explains that trade users can upload CAPE Declarations, review declaration status and troubleshoot validation errors tied to IEEPA duty refund claims.
Phase 1 was narrower.
CBP’s CAPE guidance explains that the first phase applied to certain unliquidated entries and certain entries no more than 80 days past liquidation.
Phase 2 expands that framework to a new category: reconciliation-flagged entries. Specifically, recent guidance on the June 29 rollout states that Phase 2 covers entry types 01, 02 and 06 that are flagged for reconciliation where no corresponding type 09 reconciliation entry has been filed.
In other words: Phase 1 focused on entries that could be handled without the additional reconciliation issue. Phase 2 addresses entries that were flagged for reconciliation but had not yet moved into the reconciliation filing stage. In other words, Phase 2 does not replace Phase 1; it adds a new lane for entries that were previously more difficult to process through CAPE because of reconciliation status.
The expansion is still limited. A June 2026 analysis of the refund litigation explains that Phase 2 applies only where the entry is unliquidated or liquidated within 80 days of the Phase 2 filing date and where the type 09 reconciliation entry has not yet been filed. That means importers with older liquidated entries, or entries where reconciliation has already been filed, may still fall outside the current phase.
The importers most directly affected by Phase 2 are those with IEEPA-duty entries that were flagged for reconciliation but have not yet had a type 09 reconciliation entry filed.
A June 2026 customs advisory described the new functionality as allowing reconciliation-flagged entry types 01, 02 and 06 to be submitted for CAPE processing only if the type 09 reconciliation has not yet been filed.
Eligibility therefore depends on several conditions:
The importer must have paid IEEPA duties on the entries at issue
The entries must be eligible under CAPE’s timing rules
The entries must be flagged for reconciliation
And, most importantly for Phase 2, the type 09 reconciliation must not already be on file.
A June 2026 update on the CAPE expansion warned that once the reconciliation entry is filed, the underlying entries can be locked out of this phase of CAPE processing.
For importers, Phase 2 is a meaningful expansion, but not an automatic refund event.
It creates a new opportunity to bring reconciliation-flagged entries into CAPE, but only if the importer can identify the right entries, confirm reconciliation status, verify liquidation timing and submit a valid CAPE Declaration through ACE.
Phase 2 also adds urgency. Importers should not assume that reconciliation-flagged entries will remain eligible indefinitely. They should immediately review ACE data, coordinate with customs brokers, identify entries where IEEPA duties were paid, determine whether a type 09 reconciliation has already been filed and prepare CAPE Declarations where eligible. CBP’s IEEPA Refund Fact Sheet also emphasizes that importers should have an active ACE Portal account, refund-specific bank account information and a compiled list of entries on which IEEPA duties were paid.
For now, IEEPA Phase 2 is implemented, but eligibility is narrow and timing-sensitive. Importers should identify reconciliation-flagged entries, confirm whether the type 09 reconciliation has already been filed, check liquidation timing, verify ACE access and refund readiness, and prepare CAPE Declarations where eligible. Phase 2 is not a passive refund event; it is a compliance-driven filing opportunity where the order of operations can determine whether an entry qualifies.
Since the Supreme Court ruling against the IEEPA tariffs Freight Right, a licensed customs brokerage, has been helping new and existing customers recover the tariffs they paid to the US government. The initial evaluation is free for the importer. The service, also, helps customers troubleshoot ACE and CAPE account issues, reconcile entries from multiple customs brokers and more.
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