CBP Updates IEEPA Reconciliation FAQ with New CAPE Filing Guidance
U.S. Customs and Border Protection (CBP) updated its IEEPA FAQ page on May 26, 2026, adding two important responses related to reconciliation filings and CAPE refund processing.
The update provides additional guidance for importers, customs brokers, and trade participants managing entries impacted by IEEPA duties and CAPE declarations.
CBP Advises Trade to Delay Certain Reconciliation Filings
One of the most significant updates involves CBP’s recommendation regarding reconciliation entry filings (Entry Type 09).
According to CBP, the agency is currently developing a phased solution for processing entries flagged for reconciliation that are included in CAPE declarations. This applies to unliquidated or recently liquidated entries (not more than 80 days beyond liquidation) involving Entry Types 01, 02, and 06 where an Entry Type 09 reconciliation has not yet been filed.
CBP stated that the CAPE process itself does not prevent reconciliation activity. However, the agency is recommending that the trade community delay reconciliation filings unless the filing deadline is within 30 days of expiring. This recommendation appears intended to allow CAPE declarations to process first before additional IEEPA duties are deposited and potentially refunded later.
Guidance for Reconciliation Deadlines Approaching Expiration
CBP also clarified what importers and brokers should do if a reconciliation filing deadline is approaching and the reconciliation would normally increase IEEPA duties.
In those situations, CBP advised filers to:
- File the reconciliation entry
- Deposit the applicable duties, taxes, and fees owed
- Exclude the increased IEEPA duties
This guidance may provide importers with an opportunity to avoid depositing additional IEEPA duties that could later require refund processing.
Additional CAPE and ACE Guidance Expected
CBP noted that it is continuing to work on solutions for reconciliation entries that have already been filed and plans to issue additional guidance through future Cargo Systems Messaging Service (CSMS) notices as new phases are implemented.
As CAPE processing and ACE procedures continue evolving, importers and customs brokers should closely monitor filing timelines, reconciliation requirements, and CBP guidance updates.
Radius International continues monitoring CBP announcements, CAPE developments, and ACE updates to help customers stay informed and prepared in an evolving trade environment.
CBP IEEPA FAQ Page: https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ
