U.S. Customs and Border Protection (CBP) has introduced Phase 1 of its new CAPE (Consolidated Administration and Processing of Entries) system, marking an important step toward processing refunds tied to expired IEEPA tariffs.
While this update provides more clarity, the rollout is limited and importers should understand what qualifies and what to expect.
What’s Included in Phase 1
CAPE Phase 1 will apply to:
- Unliquidated entries
- Entries still within the 90-day voluntary reliquidation window
CBP will also accept entries with statuses such as:
- Suspended
- Extended
- Under Review
In many cases, refunds will still be issued through the normal liquidation process, rather than immediately.
What’s Not Included (Yet)
The following entries are not eligible in Phase 1:
- Finally liquidated entries
- Entries under protest
- Drawback or reconciliation entries
- Certain AD/CVD entries pending liquidation
CBP has indicated that future phases may expand to include some of these categories.
Processing Timeline & Compliance
CBP may take up to 45 days to review and process accepted entries.
They have also confirmed that entries will be reviewed for compliance, including:
- Classification
- Value
- Country of origin
- Supporting documentation
Refunds may be delayed or adjusted if issues are identified.
What This Means for Importers
This update introduces a structured path toward refunds—but it does not eliminate uncertainty.
Importers should:
- Carefully evaluate timing for protests vs. waiting for CAPE
- Ensure all entry documentation is accurate and complete
- Stay informed as additional phases are released
How Radius International Can Help
As regulatory updates continue to evolve, Radius International helps clients stay prepared by:
- Monitoring CBP changes
- Supporting compliance and documentation accuracy
- Providing guidance on best practices for import processes
While we do not process refunds directly, we work to ensure your shipments are positioned correctly as new developments unfold
