CAPE Portal Deadlines: What You Must File Before the Windows Close
CBP's CAPE portal is actively processing IEEPA tariff refunds across three phases. Each phase has eligibility rules and sequence requirements that can permanently disqualify entries if missed. TariffIQ™ maps your entries to the right phase and sequences your filing correctly.
The Supreme Court’s February 20, 2026 ruling in Learning Resources v. Trump held IEEPA tariffs unlawful, opening $166 billion in refunds for 330,000 importers of record. As of June 29, 2026, $71.06 billion has been certified and sent to Treasury through CBP’s CAPE system.
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. As of June 29, 2026, 18.1 million entries have cleared validation under Phase 1.
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 — Targeting late July 2026. Covers finally liquidated entries — those liquidated more than 80 days before the CAPE filing date. Under DOJ's current position, Phase 3 is limited to approximately 4,000 importers who filed individual Section 1581(i) lawsuits at the CIT.
The Type 09 Sequence Trap
The Filing-Sequence Trap That Costs Importers Their Phase 2 Refund
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.
Warehouse Entry Rule
Warehouse Entry Rule Change: Effective July 7, 2026
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.
ACH & Banking
ACH Enrollment: 8,384 Certified Refunds Stuck at Treasury
CBP's July 1, 2026 CIT status declaration confirms that 8,384 certified refunds are sitting at Treasury solely because the importer — or its Form 4811 designee — never provided ACH banking information in ACE. 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.
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Important Note: CAPE Declarations cannot be amended once accepted in ACE. Additional entries must be submitted in a new Declaration. Triple-check your entry list, HTS codes, and filing sequence before submission. Once filed and validated, the Declaration is final.
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Informational only. Not legal, tax, or financial advice. The Tariff Bureau LLC is not a law firm, is not a licensed customs broker, and is not affiliated with CBP or any U.S. government agency. The IEEPA statute of limitations accrual date remains legally unsettled. Consult qualified trade counsel for your specific situation.