CAPE Portal Deadlines: What You Must File Before the Windows Close

Phase 1 — Active since April 20, 2026. Covers unliquidated entries and entries liquidated within 80 days of the CAPE Declaration filing date. No Type 09 restriction. This is the broadest phase and covers approximately 63% of total IEEPA entries. Per a July 1, 2026 CBP status declaration, 18.1 million entries had cleared validation under Phase 1 as of June 29; by July 10, cumulative repayments across all phases had grown to $86.3 billion, with the pace continuing to accelerate.

Phase 2 — Active since June 29, 2026. Covers reconciliation-flagged entries (Types 01, 02, 06) where the Type 09 reconciliation entry has not yet been filed. Once the Type 09 is filed, those entries drop out of Phase 2 into a future phase. If your reconciliation deadline is more than 30 days away, file your CAPE Declaration first. If under 30 days, file the Type 09 first per CBP guidance.

Phase 3 — CBP progress report due August 4, 2026. Covers finally liquidated entries — those liquidated more than 80 days before the CAPE filing date. CBP testified at the June 9 CIT hearing that Phase 3 programming would be ready by end of July 2026. On July 17, 2026, Judge Eaton ordered CBP to reliquidate such entries, but limited that relief to the roughly 3,700 companies whose IEEPA cases were already on his docket. The new lead case is now Freestyle World, Inc. v. United States (Court No. 26-01088), after Euro-Notions voluntarily dismissed on July 16. Under DOJ's current position, Phase 3 is limited to importers who filed individual Section 1581(i) lawsuits at the CIT — importers who have not filed a CIT complaint are not yet covered. CBP must file a Phase 3 progress report by 5:00 PM EDT on August 4, 2026, with a closed settlement conference on August 5. DOJ is also opposing class certification that could broaden Phase 3 access — oral arguments are set for August 6 and August 19.

This is the most common and costly mistake in CAPE Phase 2 filings. Once your Type 09 reconciliation entry is filed in ACE, the underlying entries immediately drop out of Phase 2 eligibility and into a future, slower phase. The CAPE system checks whether a Type 09 is on file at the moment of Declaration submission. If it is, the entry is excluded. The correct sequence: (1) File your CAPE Declaration first. (2) Wait for validation confirmation. (3) Then file the Type 09. The one exception: if your reconciliation deadline is within 30 days, CBP guidance says to prioritize the Type 09 to avoid missing your filing window. In that case, those entries move to a future CAPE phase, not Phase 2. TariffIQ™ checks your reconciliation deadline and tells you the correct sequence for each entry before you file anything.

Per CBP CSMS #69127837 (July 2, 2026), effective July 7, 2026, warehouse entries (Entry Types 21 and 22) are no longer accepted on CAPE Declarations. Any warehouse entry submitted on a CAPE Declaration on or after that date will be rejected with an 'ENTRY TYPE NOT ALLOWED' error. Warehouse withdrawals (Entry Types 31, 32, 34, 38) continue to be accepted, since IEEPA duties were paid at the time of withdrawal, not entry. CBP will process approved refunds on warehouse withdrawals upon liquidation of the associated warehouse entry.

Critical transition alert: Warehouse entries (Types 21/22) that were accepted on a CAPE Declaration between April 20 and July 6, 2026 without a corresponding warehouse withdrawal submission will not be reliquidated with an IEEPA duty refund. Filers in this position must submit a new, separate CAPE Declaration covering the warehouse withdrawals on which duties were actually paid.

CBP's July 13, 2026 CIT status declaration confirmed that 9,837 certified refunds are sitting at Treasury solely because the importer — or its Form 4811 designee — never provided ACH banking information in ACE, up from 8,384 reported just two weeks earlier. These refunds are approved. They are fully certified. They are ready to pay. The only thing stopping disbursement is a missing bank account number. If you have filed a CAPE Declaration and are awaiting payment, log into your ACE Secure Data Portal account immediately and verify your ACH banking information is complete and active. If you are using a Form 4811 designee (such as The Tariff Bureau) for ACH receipt, confirm the designee's banking details are properly enrolled.