CAPE Phase 2 opened new refund eligibility on June 29, 2026. Learn the filing rules, the risks and how AAS can help you avoid a rejected claim.
CAPE Phase 2 is now live. United States Customs and Border Protection deployed the second phase of its Consolidated Administration and Processing of Entries (CAPE) system on June 29, 2026, opening the door for a new group of Importers of Record to submit refund claims for tariffs collected under the International Emergency Economic Powers Act (IEEPA).
If your business paid IEEPA duties and has entries tied to reconciliation, this update may directly affect your IEEPA tariff refund. But launch day is only the start. This phase comes with its own filing rules, eligibility limits and risk of costly mistakes if entries are not prepared correctly.
Here is what changed, why it matters and what to do next.
CAPE Phase 2 is the second stage of CBP's CAPE tool, the electronic system built inside the Automated Commercial Environment (ACE) to process IEEPA duty refunds. CBP launched Phase 1 in April 2026 to cover unliquidated entries and entries within 80 days of liquidation.
This second stage was designed to open the CBP CAPE refund process to a category Phase 1 did not touch: Entries flagged for reconciliation. It's one part of the broader IEEPA Tariff Refund Recovery program CBP is building out to return duties collected under a law the Supreme Court has already ruled unlawful.
CBP confirmed the IEEPA Phase 2 launch date as June 29, 2026, consistent with its filings to the Court of International Trade. It marks the second major expansion of the CBP CAPE refund process since CBP first opened the system in April, and the new phase now runs alongside Phase 1, which has been active since April 20, 2026.
At a June 9, 2026 hearing before the Court of International Trade, CBP's executive assistant commissioner for trade, Susan Thomas, estimated that this rollout covers roughly $28.7 billion in additional refunds tied to about 2.8 million entries, on top of the nearly $95 billion CBP had already accepted into CAPE as of early June, most of it processed through Phase 1.
Phase 2 accepts entries flagged for reconciliation, specifically entry types 01, 02 and 06, where the related Type 09 reconciliation entry has not yet been filed. The entries covered must also fall within the same unliquidated or 80-day liquidation window used in Phase 1.
Entries where a reconciliation entry has already been submitted to CBP are not included in this round. CBP has indicated those records are expected to move through a future phase. However, older reconciliation entries may still be excluded. If your business filed reconciliation entries early in the IEEPA period, before roughly May 31, 2025, those entries likely liquidated on a standard 314-day cycle.
That means they may have liquidated more than 80 days before this window opened, putting them outside the current phase despite being reconciliation-related.
Phase 1 was built for the most straightforward category: Unliquidated and recently liquidated entries. CAPE Phase 2 adds a second layer, reconciliation status, on top of the same liquidation rules.
Before you can submit a CAPE Declaration for a reconciliation-flagged entry, you need to confirm that the Type 09 has not yet been filed, that the entry is within the liquidation window and that you coordinate timing with your customs broker so the IEEPA duties are removed before the final reconciliation entry goes in. Since the filing authority runs through the Importer of Record, the broker needs that authorization in hand before anything can move.
Get that sequence wrong, and the entry can lose eligibility permanently. Once a broker files the Type 09, the underlying record is locked out of this phase for good. That is not a hypothetical. It has already happened to companies with large reconciliation exposure; see why some IEEPA tariff refunds get delayed for a real breakdown of how a mistimed filing can strand a payout.
That added complexity is already showing up in real numbers. Since Phase 1 opened, importers have run into:
These issues do not disappear with the new rollout. If anything, reconciliation entries add another point of failure, since a single miscoordinated Type 09 filing can close off a refund opportunity for good. These are not isolated problems. We've already covered a real case where reconciliation timing delayed a payout, and the pattern is becoming more common as Phase 2 brings more reconciliation entries into play.
Once CBP accepts your CAPE Declaration, you cannot amend it, so a rejected or incomplete filing means starting over and losing weeks on a refund timeline that already takes 60 to 90 days. For businesses with reconciliation entries up against their own filing deadlines, that kind of delay can cost you the window entirely, which is exactly why getting the sequencing, data and paperwork right on the first attempt matters more now than it ever did during Phase 1.
Every Importer of Record with reconciliation-flagged entries should treat this window as time-sensitive, which is a lot to manage correctly while also running daily operations. If your business lacks the internal bandwidth to manage this process alongside daily operations, Anchor Accounting Services can help. Our team identifies which entries may be eligible now, prepares CAPE-ready filing, and manages the claim through submission, monitoring and reconciliation.
With CAPE Phase 2 now live and CBP still working through Phase 1 backlogs, the businesses that move forward with a clean, well-prepared claim are now best positioned to avoid the next round of delays. Request a Recovery Review or Visit the IEEPA Resource Hub Today.
