Is CAPE Phase 2 live?

Yes. Phase 2 went live on June 29, 2026, per CSMS #68340863. It covers reconciliation-flagged entries (types 01, 02, and 06 flagged for reconciliation without a filed Type 09 reconciliation entry) — roughly 2.8 million entries and approximately $28.7 billion in IEEPA duties.

Does Phase 2 cover line-level adjustments via the ES-701?

No. Phase 2 is about reconciliation-flagged entries, not line-item declarations. Early speculation that Phase 2 would be a line-level filing model did not match CBP's actual rollout.

Should I wait for Phase 3 to file?

No. File Phase 1- and Phase 2-eligible entries now. Phase 3 (finally liquidated entries) is expected in late July 2026, but its scope is contested in the government's Federal Circuit appeal — and a timely § 1514 protest is the protective path for liquidated entries in the meantime.

Refund Programs

What is CAPE Phase 2?

The CAPE expansion live since June 29, 2026 (CSMS #68340863), covering reconciliation-flagged entries — roughly $28.7B in IEEPA duties. In the context of U.S. customs and tariff recovery, understanding cape phase 2 is essential for navigating the CAPE refund process and ensuring accurate duty assessment.

Definition

CAPE Phase 2 is the expansion of the Consolidated Administration and Processing of Entries program that went live on June 29, 2026, announced in CSMS #68340863. Phase 2 covers entries flagged for reconciliation: consumption entries (types 01, 02, and 06) that carry a reconciliation flag but do not yet have a filed Type 09 reconciliation entry. These entries were excluded from Phase 1 because their duty amounts were not yet final. CBP estimates the Phase 2 population at roughly 2.8 million entries, representing approximately $28.7 billion in IEEPA duties.

How CAPE Phase 2 Relates to Tariff Refunds

Phase 2 opens CAPE recovery to importers whose entries were flagged for reconciliation — common among related-party importers with transfer-pricing adjustments and importers with pending value or trade-program claims. If your ES-003 shows reconciliation-flagged entries that Phase 1 could not accept, those entries are now declarable. Tariffi identifies reconciliation-flagged entries during ES-003 analysis and routes them into the CAPE declaration alongside Phase 1-eligible entries.

Example

A multinational importer flagged 1,400 entries for value reconciliation while its transfer-pricing adjustments were pending, so those entries could not go into a Phase 1 declaration. When Phase 2 went live on June 29, 2026, the broker declared the reconciliation-flagged entries through CAPE, adding $2.1 million in IEEPA overpayments to the importer's recovery.

Frequently Asked Questions

Is CAPE Phase 2 live?: Yes. Phase 2 went live on June 29, 2026, per CSMS #68340863. It covers reconciliation-flagged entries (types 01, 02, and 06 flagged for reconciliation without a filed Type 09 reconciliation entry) — roughly 2.8 million entries and approximately $28.7 billion in IEEPA duties.
Does Phase 2 cover line-level adjustments via the ES-701?: No. Phase 2 is about reconciliation-flagged entries, not line-item declarations. Early speculation that Phase 2 would be a line-level filing model did not match CBP's actual rollout.
Should I wait for Phase 3 to file?: No. File Phase 1- and Phase 2-eligible entries now. Phase 3 (finally liquidated entries) is expected in late July 2026, but its scope is contested in the government's Federal Circuit appeal — and a timely § 1514 protest is the protective path for liquidated entries in the meantime.

Legal References

CSMS #68340863 — CAPE Phase 2 launch (June 29, 2026)
19 CFR Part 401 — Reconciliation

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