Why are FTZ and bonded warehouse entries excluded from CAPE Phase 1?

Foreign Trade Zone admissions and Type 21 bonded warehouse entries follow a different duty-assessment timeline than ordinary consumption entries. Duty is not paid at admission to an FTZ or warehouse — it is paid at withdrawal for consumption, which can occur months or years after admission. CBP's Phase 1 workflow is built around entry-summary-level refund calculations on entries where the duty was assessed and paid as a single event. FTZ withdrawals (Type 06) and warehouse withdrawals (Type 22) during the IEEPA-tariff period (February 1, 2025 through February 24, 2026) are eligible in concept but require additional accounting logic that CBP has deferred to a later phase.

What is the difference between PF and NPF FTZ admissions for IEEPA purposes?

FTZ admissions are classified as either Privileged Foreign (PF) or Non-Privileged Foreign (NPF). PF status fixes the duty rate at admission — so merchandise admitted to an FTZ in PF status during the IEEPA period had the IEEPA rate locked in even if it was withdrawn later. NPF status determines the rate at withdrawal — so merchandise admitted before IEEPA but withdrawn during IEEPA in NPF status was assessed IEEPA duties at withdrawal. Both PF admissions during IEEPA and NPF withdrawals during IEEPA generate IEEPA duty payments that may be recoverable in CAPE Phase 2 once CBP publishes the workflow. Document the admission election (PF vs NPF) for every relevant lot.

What about manufacturing in an FTZ — does that change the IEEPA refund posture?

Yes. Manufacturing FTZs add another layer because the merchandise withdrawn for consumption may be classified differently from the merchandise admitted (substantial transformation). For PF-elected components used in manufacturing, the IEEPA rate was fixed at admission of those components even if the finished good has a different classification. For NPF, the finished good's classification at withdrawal drives the rate. The CAPE refund analysis has to track not just the admission and withdrawal records but the manufacturing flow between them. This is the most complex FTZ scenario and almost always requires outside counsel and an FTZ operator with detailed inventory accounting.

How do bonded warehouse withdrawals work for IEEPA refund purposes?

Type 21 bonded warehouse entries allow merchandise to be stored under CBP supervision for up to 5 years before withdrawal. When merchandise is withdrawn for consumption (becoming a Type 22), duties are assessed at the rate in effect at the time of withdrawal. Withdrawals that happened between February 1, 2025 and February 24, 2026 had IEEPA duties assessed and paid. Those payments are conceptually CAPE-eligible but excluded from Phase 1 because the warehouse-entry accounting links the original Type 21 admission to the Type 22 withdrawal in a way that CBP's Phase 1 query cannot yet handle cleanly. Run a Type 22 report for the IEEPA period now so the data is ready when Phase 2 opens.

Should I file a protest on FTZ or warehouse withdrawals while waiting?

Yes, where the 180-day protest window from liquidation is still open. FTZ Type 06 withdrawals and warehouse Type 22 withdrawals liquidate like ordinary consumption entries, and the protest deadline runs from that liquidation date. Waiting passively for Phase 2 may forfeit the protest right on entries whose 180-day window closes before Phase 2 opens. Protective protests are inexpensive insurance and preserve the option of a CIT challenge later if Phase 2 ends up not covering your specific posture. Trade counsel should run the deadlines for every Type 06 and Type 22 in the IEEPA window.

FTZ Admissions and Warehouse Entries: Where IEEPA Refunds Stand in 2026

Foreign Trade Zones and bonded warehouses sit in a deferred-duty world by design — duties are not assessed at admission, they are assessed at withdrawal for consumption. That timing mismatch is exactly why CBP excluded these entries from CAPE Phase 1 and has not yet published the Phase 2 workflow that will cover them. If you operate an FTZ or use bonded warehouses meaningfully, your IEEPA refund eligibility is real but it is on a different track from the importers who file ordinary consumption entries.

This post explains how the IEEPA tariffs interacted with FTZ and warehouse entries, what records to preserve now, and the protest backstop you should run while waiting.

FTZ admissions and bonded warehouse entries IEEPA refund eligibility for CAPE Phase 2

How IEEPA Hit FTZ and Warehouse Entries

IEEPA tariffs were in effect on consumption entries between February 1, 2025 and February 24, 2026. For ordinary consumption (Type 01) entries, the duty was paid at entry summary, the entry liquidated within roughly 314 days, and the books closed.

For FTZ and bonded warehouse merchandise, the IEEPA duty payment happened at a different point:

FTZ Privileged Foreign (PF) admissions during IEEPA: rate was fixed at admission. Merchandise admitted with PF election between February 2025 and February 2026 carries an IEEPA-rate duty obligation that is paid at withdrawal.
FTZ Non-Privileged Foreign (NPF) withdrawals during IEEPA: rate was determined at withdrawal. Anything admitted under NPF and withdrawn during the IEEPA window paid the IEEPA rate at the Type 06 withdrawal entry.
Bonded warehouse withdrawals (Type 22) during IEEPA: duty was assessed at the time of withdrawal at the in-effect rate. Type 22 withdrawals between February 2025 and February 2026 paid IEEPA duties.

Each of these scenarios creates a real IEEPA duty payment that is, in concept, refundable. The reason CBP excluded them from Phase 1 is procedural, not substantive.

Why Phase 1 Could Not Handle Them

CBP’s Phase 1 workflow runs an entry-summary-level query: pull the entry summary, identify the IEEPA Chapter 99 duty line, refund that line. For Type 06 FTZ withdrawals and Type 22 warehouse withdrawals, the IEEPA-duty calculation depends on:

The original admission record (which can be months or years prior)
The PF or NPF election on the admission
For manufacturing FTZs, the inventory accounting that links admitted inputs to withdrawn outputs
The withdrawal entry itself

Phase 1 cannot link those records cleanly enough to refund without manual review. CBP has indicated that Phase 2 will address excluded categories, but no specific FTZ or warehouse workflow has been published as of May 2026.

What to Document Now

The work that pays off when Phase 2 opens is identifying every IEEPA-affected admission and withdrawal in your portfolio and pulling the supporting records before they age out of operational systems.

For FTZ operators, run inventory and movement reports covering:

All PF admissions between February 1, 2025 and February 24, 2026 (with admission CF-214s and rate-fixing documentation)
All NPF withdrawals (Type 06) during the same window
For manufacturing FTZs: the production records linking admitted inputs to withdrawn outputs

For bonded warehouse users:

All Type 22 withdrawals during the IEEPA window
The original Type 21 entries those withdrawals drew from
Any manipulation, manufacturing, or repackaging records under 19 CFR Part 19

Use our pre-counsel documentation checklist as a starting point, then layer on the FTZ-specific or warehouse-specific records.

File Protective Protests Where Deadlines Are Approaching

The 180-day protest deadline runs from the liquidation of the Type 06 or Type 22 entry — not from CBP’s CAPE rollout schedule. Entries that liquidated in mid-2025 may already be approaching the protest deadline. If you wait passively for Phase 2 specifics, you may forfeit the protest right entirely on those entries.

Protective protests under 19 USC 1514 are inexpensive insurance. They preserve the right to argue for full IEEPA recovery if Phase 2 turns out not to cover your specific FTZ or warehouse posture, and they preserve the option of a CIT challenge later. Our protest filing guide walks through the mechanics. Coordinate with your FTZ counsel or trade attorney on which entries to file on first.

Why Outside Counsel Matters Here

FTZ and warehouse refunds are among the most complex IEEPA refund scenarios because the analysis spans multiple regulatory frameworks: 19 USC 1311 (warehouse), 19 USC 81 (FTZ), 19 CFR Part 19 (warehouse manipulation), 19 CFR Part 146 (FTZ), and the IEEPA tariff regime itself. In-house customs teams that handle ordinary consumption entries comfortably often need outside counsel for the FTZ-CAPE or warehouse-CAPE intersection.

The cost of getting it wrong is significant: incorrectly filed CAPE declarations on FTZ withdrawals can be rejected, double-claim attempts trigger CBP scrutiny, and protest deadlines lost cannot be recovered. The cost of getting it right is a counsel engagement on a portfolio that often has six- or seven-figure IEEPA exposure.

What to Watch from CBP

CBP has not committed to a Phase 2 publication date as of May 2026. Watch for CSMS messages and updates to the CBP IEEPA Refunds page. Our CSMS message index and the CAPE Update Tracker on the home page are kept current with each new official checkpoint.

If you operate an FTZ or use bonded warehouses with material IEEPA exposure, request a free assessment and we will connect you with vetted trade counsel familiar with FTZ and warehouse refund coordination.