What is Warehouse Entry?
A customs entry (types 21/22) for goods placed in a bonded warehouse, deferring duty until withdrawal. Not CAPE-eligible since July 7, 2026 — refunds run through the withdrawal entries instead. In the context of U.S. customs and tariff recovery, understanding warehouse entry is essential for navigating the CAPE refund process and ensuring accurate duty assessment.
Definition
A warehouse entry is a customs entry filed when imported goods are placed into a CBP-bonded warehouse rather than entering the U.S. for immediate consumption. Duty payment is deferred until the goods are withdrawn for domestic use. The warehouse entry allows importers to store goods for up to 5 years, during which time they can be manipulated, repackaged, or tested without triggering duty assessment. If goods are exported directly from the warehouse, no U.S. duties are owed. Warehouse entries require a bonded warehouse operator with an active CBP permit.
How Warehouse Entry Relates to Tariff Refunds
Warehouse entries defer duty payment. If tariff rates change while goods are in the bonded warehouse, the importer pays the rate in effect at the time of withdrawal, not the rate at the time of warehouse entry. This can eliminate the need for a CAPE refund entirely — the importer simply waits for the lower rate before withdrawing goods for consumption. Where IEEPA duty was already paid, the CAPE claim must target the right entry type: effective July 7, 2026 (CSMS #69127837), CBP rejects warehouse entry types 21 and 22 from CAPE with 'ENTRY TYPE NOT ALLOWED.' The duty remains refundable via the withdrawal entries (types 31, 32, 34, or 38), which is where duty was actually assessed. Type 21/22 declarations filed between April 20 and July 6, 2026 without withdrawal references will not be reliquidated — new declarations citing the withdrawal entries are required.
Example
An importer places $1 million of Chinese goods in a bonded warehouse while IEEPA tariff rates are under negotiation. Three months later, the rate drops from 25% to 10%. The importer withdraws the goods and pays 10% ($100,000) instead of 25% ($250,000), saving $150,000 without needing a CAPE refund. For earlier withdrawals made at the 25% rate, the broker's CAPE declaration lists the type 34 withdrawal entry numbers — not the original type 21 warehouse entry.
Frequently Asked Questions
- What is the advantage of a warehouse entry over consumption entry?
- Warehouse entries defer duty payment and allow the importer to wait for favorable rate changes, re-export without paying duties, or hold inventory without tying up capital in duty payments.
- Can any warehouse accept a warehouse entry?
- No. Only CBP-bonded warehouses with an active permit can accept warehouse entries. The warehouse operator must meet CBP security and record-keeping requirements.
- Are warehouse entries CAPE-eligible?
- Types 21 and 22 are not — CAPE rejects them with 'ENTRY TYPE NOT ALLOWED' effective July 7, 2026 (CSMS #69127837). The IEEPA duty is still refundable through the withdrawal entries (types 31/32/34/38), where the duty was actually paid. Tariffi's analysis maps warehouse entries to their withdrawals so the declaration cites the correct entry numbers.
Related Terms
Legal References
- 19 U.S.C. § 1557 — Warehouse Entry
- 19 CFR Part 144 — Warehouse Entries
- CSMS #69127837 — Warehouse entry types 21/22 rejected from CAPE (July 7, 2026)
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