$86 billion in IEEPA refunds already sent to Treasury. Phase 2 is live for reconciliation entries and Phase 3 is still in development — while nearly one-third of declarations fail validation. Here's how to get yours right the first time.
CAPE Update Tracker
Use this as the quick context layer before you rely on CAPE alone. It keeps the live phase, latest official checkpoint, and main current limitation in one place.
Current phase
CBP deployed Phase 2 reconciliation functionality on June 29, 2026. The initial lane accepts Entry Types 01, 02, and 06 that are flagged for reconciliation, have no Entry Type 09 reconciliation on file, and remain unliquidated or within 80 days of liquidation. CBP reported 1.6 million reconciliation-flagged entries successfully filed by June 30.
Last official update reviewed
The July 15 CIT order says CAPE Phase 3 development is ongoing and that the court will issue a future order directing CBP to reliquidate certain finally liquidated entries in roughly 3,700 IEEPA cases assigned to the court. The July 13 Lord Declaration from CBP reports 9,837 refunds still held for missing ACH information and approximately $86.3 billion completed and sent to Treasury as of July 10.
Most important limitation
CAPE expansion does not pause the 180-day protest deadline or guarantee refunds for finally liquidated entries. The July 15 CIT order says Phase 3 is still in development and that a future order will outline a reliquidation procedure for certain finally liquidated entries in roughly 3,700 court-assigned IEEPA cases; non-litigant eligibility remains disputed. File protective protests where the window is open and seek trade-counsel review for material final claims.
CAPE simplifies the intake process, but CBP still validates the entries, recalculates duties, and controls when refunds are released.
Confirm the entry has IEEPA Chapter 99 duties and is either still unliquidated or not more than about 80 days past liquidation. Use our interactive checker to verify.
Set up ACE access, enroll ACH refunds, and prepare an entry-number-only CSV that matches your importer or filing account.
Upload up to 9,999 entry numbers, clear ACE validations, and monitor consolidated refunds through the new CAPE reporting workflow.
Our guide is updated from CBP CSMS releases and cross-checked against current trade commentary.
As of July 10, 2026, CBP had accepted approximately $121.75 billion in potential and certified refunds for CAPE processing and sent approximately $86.3 billion to the Treasury for disbursement. Average turnaround remains ~18 days for clean entries.
Source: CBP Lord Declaration, CIT (July 13, 2026)
Only the importer of record or the broker that filed the entry summary can submit a CAPE declaration, and the upload is limited to entry numbers only.
Source: CBP CSMS #68340863
ACH refunds are mandatory. CBP's July 13 declaration confirms 9,837 approved refunds remain stuck because importers have not provided valid ACH banking information — check yours before you file.
Source: CBP Lord Declaration, CIT (July 13, 2026); CSMS #68179006
For standard Phase 1 claims, CBP reports an average 18-day refund turnaround (~14 days for electronics/consumer goods) once entries clear validation — significantly faster than the published 60–90-day window.
Source: CBP May 26, 2026 CIT Progress Report; CSMS #68340863
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New analysis as CAPE Phase 1 unfolds — eligibility shifts, ACE workflow changes, and refund timing observations.
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