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Refund Programs

What is CAPE Phase 2?

The upcoming expanded CAPE program phase for processing complex refund claims including line-level adjustments. 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 planned expansion of the Consolidated Administration and Processing of Entries program to support line-level adjustments and more complex refund claims. While Phase 1 operates at the entry-number level (entire entries are declared for refund), Phase 2 will allow importers to claim refunds on specific line items within an entry — necessary for entries where only some products qualify for tariff reduction. Phase 2 is expected to use the ES-701 line-level data from ACE.

How CAPE Phase 2 Relates to Tariff Refunds

Phase 2 will expand refund eligibility to importers whose entries contain a mix of qualifying and non-qualifying products. Tariffi is building Phase 2 readiness into its platform, including ES-701 line-level parsing and per-product HTS analysis, so claims can be filed as soon as CBP opens the Phase 2 window.

Example

An importer has an entry with 50 line items: 30 products from China subject to Section 301, and 20 from Vietnam with no additional tariffs. Phase 1 cannot handle this mixed entry. Phase 2 will allow the broker to declare only the 30 China-origin lines for refund.

Frequently Asked Questions

When will CAPE Phase 2 launch?
CBP has not announced a specific date. Phase 2 guidance is expected after Phase 1 processing stabilizes. Monitor CBP's CAPE FAQ page for updates.
Should I wait for Phase 2 to file?
No. File Phase 1 claims now for entries that fully qualify. Phase 2 will address the subset of entries that need line-level treatment.

Related Terms

CAPEConsolidated Administration and Processing of Entries — CBP's portal for filing tariff refund declarations under IEEPA and Section 301.CAPE Phase 1The initial CAPE program window accepting CSV-based refund declarations for IEEPA and Section 301 tariff overpayments.ES-701Detailed entry line item report from ACE, showing individual line-level data for each import entry.HTS CodeHarmonized Tariff Schedule code — the 10-digit number that determines the duty rate on imported goods in the U.S.ClassificationThe process of assigning an HTS code to imported goods to determine the applicable duty rate.

Legal References

  • CBP CAPE Program FAQ (April 2026) — Phase 2 guidance forthcoming

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