What are CAPE Phase 2 reconciliation entries?
Quick answer
CAPE Phase 2, live since June 29, 2026 (CSMS #68340863), covers entries flagged for reconciliation: consumption entries (types 01, 02, and 06) that carry a reconciliation flag but have no filed Type 09 reconciliation entry. CBP estimates roughly 2.8 million such entries, representing about $28.7 billion in IEEPA duties, are now declarable through CAPE.
Detailed Answer
CAPE Phase 2 went live on June 29, 2026, announced in CSMS #68340863. It opens the CAPE refund path to a category of entries Phase 1 could not accept: entries flagged for reconciliation.
What a reconciliation flag is. CBP's reconciliation program lets importers file an entry with estimated data (typically value, classification, or trade-program claims) and finalize it later with a Type 09 reconciliation entry — common for related-party importers whose transfer prices adjust after entry. While the flag is open, the entry's duty amount is not final.
Why these entries were excluded from Phase 1. Phase 1 (live April 20, 2026) processed entries whose duty amounts CBP could calculate directly from its own records — unliquidated entries and entries within about 80 days of liquidation. A reconciliation-flagged entry without a filed Type 09 has an unsettled duty basis, so CBP deferred them to their own phase.
What Phase 2 covers:
- Consumption entry types 01, 02, and 06
- Flagged for reconciliation, with no Type 09 reconciliation entry yet filed
- Approximately 2.8 million entries and about $28.7 billion in IEEPA duties, per CBP
What Phase 2 is not. Early speculation suggested Phase 2 would be a "line-level adjustment" filing model built on ES-701 data. CBP's actual rollout is about reconciliation-flagged entries — declarations remain at the entry-number level, and CBP calculates the refund from its records.
What to do if you have reconciliation-flagged entries. They are now declarable. Tariffi's ES-003 analysis identifies reconciliation-flagged entries automatically and routes them into your CAPE declaration alongside Phase 1-eligible entries; your licensed broker partner reviews and files, as always, under 19 U.S.C. § 1641. If you filed a Phase 1 declaration and had reconciliation-flagged entries held back, upload your latest ES-003 at tariffi.io/intake/start to capture them.
Related Questions
What is the CAPE program?
CAPE (Consolidated Administration and Processing of Entries) is CBP's electronic program for processing IEEPA tariff refund declarations. Importers who overpaid IEEPA tariffs submit CAPE declarations through the ACE portal. (Section 301 duties are not refundable through CAPE — that is a separate USTR-exclusion path.) Tariffi automates the data preparation; your licensed customs broker partner transmits the declaration under their ABI filer code.
What is CAPE Phase 3?
CAPE Phase 3 is the expected final phase of CBP's IEEPA refund program, covering finally liquidated entries — approximately $11.4 billion in duties. CBP has indicated late July 2026, but the scope is contested: DOJ is appealing the CIT's universal-refund order, and Phase 3 could be narrowed. A § 1514 protest within 180 days of liquidation is the protective path.
Am I eligible for an IEEPA tariff refund?
You may be eligible if you are a U.S. importer of record who paid tariffs under the International Emergency Economic Powers Act on qualifying entries within the CAPE lookback window. Upload your ES-003 entry-summary CSV and Tariffi analyzes each entry's eligibility automatically — no commitment required to check.
How do I know if my entries are eligible?
Upload your ES-003 entry-summary CSV at tariffi.io/intake/start. Tariffi's analysis engine automatically cross-references each entry's HTS codes against the CAPE-eligible tariff schedule, checks liquidation status, identifies disqualifying factors, and shows you a per-entry breakdown of eligible amounts and applicable fee tiers.
Need help?
Upload your ES-003 to see how much you could recover, or talk to our team.