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Refund Programs

What is CAPE Phase 1?

The initial CAPE program window accepting CSV-based refund declarations for IEEPA tariff overpayments. In the context of U.S. customs and tariff recovery, understanding cape phase 1 is essential for navigating the CAPE refund process and ensuring accurate duty assessment.

Definition

CAPE Phase 1 is the initial program window for the Consolidated Administration and Processing of Entries system. It accepts entry-number-level refund declarations for IEEPA tariff overpayments (HTS 9903.01 trafficking and 9903.02 reciprocal duties). Under Phase 1, importers (through their brokers) submit a CSV listing qualifying entry numbers. CBP validates each entry, confirms eligibility, and processes refunds on a rolling basis. Phase 1 was launched in April 2026 with a pass rate of approximately 97.8% on initial submissions. Common rejection reasons include drawback conflicts, inability to calculate duty differentials, and incomplete Post-Summary Correction (PSC) records.

How CAPE Phase 1 Relates to Tariff Refunds

Phase 1 was the first live CAPE window and remains the primary path for unliquidated entries and entries within about 80 days of liquidation; Phase 2 (reconciliation-flagged entries) joined it on June 29, 2026. Tariffi's ES-003 analysis identifies entry numbers, confirms eligibility against CBP's published criteria, and outputs a CAPE-compliant CSV. Most importers with straightforward IEEPA exposure can recover the majority of their overpayments through Phase 1 alone. (Section 301 overpayments are not part of CAPE — they are recovered separately through USTR exclusions, Post-Summary Correction, or a section 1514 protest.)

Example

A broker submits a Phase 1 CSV with 500 entry numbers. CBP processes the declaration within two weeks. Of the 500 entries, 489 are approved (97.8% pass rate), 6 are rejected for drawback conflicts, and 5 require PSC review. The importer receives $1.2 million in refunds via ACH.

Frequently Asked Questions

What is the CAPE Phase 1 pass rate?
As of April 2026, the initial pass rate was approximately 97.8%. Most rejections are due to drawback conflicts, PSC-incomplete entries, or entries where CBP cannot calculate the duty differential.
How long does a Phase 1 refund take?
CBP processes Phase 1 declarations on a rolling basis. Most importers see refunds within 60-90 days, though complex cases may take longer.

Related Terms

CAPEConsolidated Administration and Processing of Entries — CBP's portal for filing IEEPA tariff refund declarations.CAPE Phase 2The CAPE expansion live since June 29, 2026 (CSMS #68340863), covering reconciliation-flagged entries — roughly $28.7B in IEEPA duties.CAPE Phase 3The expected final CAPE phase for finally liquidated entries (~$11.4B), anticipated late July 2026 and contested in the government's Federal Circuit appeal.ES-003Entry Summary report exported from the CBP ACE portal, containing historical import data used for refund claims.ACEAutomated Commercial Environment — CBP's online portal for trade processing, entry filing, and data retrieval.LiquidationCBP's final determination of the correct rate of duty and total amount owed on an import entry.DeclarationA formal statement submitted to CBP declaring the contents, value, and classification of imported goods.

Legal References

  • CBP CAPE Phase 1 FAQ (April 2026)

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