How to Handle a Type 31 Entry Not Reliquidated After 90 Days
CAPE accepted a Type 31 warehouse withdrawal, but ACE shows no refund after 90 days? Check the warehouse entry, ACE reports, and protest deadline.
A reader recently contacted us with a specific CAPE problem.
Several Type 31 warehouse withdrawals had been submitted under CAPE Phase 1 before the 80-day filing cutoff. ACE showed the claim status as CAPE Accepted. But more than 90 days later, the entries still did not appear to have been reliquidated, and the refund amount, refund number, refund date, and refund status were all blank.
The reader’s question was straightforward:
Do we need to file a protest to get these Type 31 entries reliquidated?
This is unlikely to be an isolated case. Type 31 warehouse withdrawals follow a different liquidation path from ordinary consumption entries, but the CAPE screen does not explain that difference. An importer can therefore see “Accepted,” wait 90 days, and reasonably conclude that something has gone wrong.
Here is how we would analyze the situation and what an importer should do next.
First, Understand What CAPE Accepted Means
A CAPE declaration receives a claim number after it passes file validation and the accepted entries pass the applicable entry-level checks.
That makes CAPE Accepted an important status, but it is not a payment confirmation. It does not necessarily mean that:
- CBP has completed the liquidation or reliquidation;
- the IEEPA Chapter 99 duty line has been removed from the entry;
- a refund amount or refund number has been created;
- Treasury has received the refund; or
- ACH payment has been issued.
In the reader’s example, the blank refund fields were not proof that CBP had denied the claim. They showed that the refund had not yet reached the visible payment stage.
There is also an important distinction between a declaration-level status and an entry-level result. If a declaration contains multiple entries, confirm that the individual Type 31 entry was accepted rather than assuming every entry moved forward because the overall declaration shows Accepted.
Why the Normal 60-to-90-Day Timeline Does Not Fit Type 31
CBP’s CAPE Phase 1 guidance says valid refunds for qualifying unliquidated entries will generally be issued within 60 to 90 days after CAPE acceptance. But the same guidance expressly excludes warehouse and warehouse-withdrawal entries from that standard timing statement.
Warehouse entries and withdrawals are not placed on the ordinary 45-day liquidation schedule. Instead, CBP says the normal warehouse liquidation process continues after all withdrawals have been made and the associated warehouse entry is ready for liquidation. See CBP CSMS #68340863.
CBP later clarified the rule specifically for bonded warehouses:
- Entry Types 31, 32, 34, and 38 remain eligible for CAPE because the IEEPA duty was paid on the withdrawal.
- Approved refunds on those withdrawals are processed upon the liquidation or reliquidation of the associated warehouse entry.
- Entry Types 21 and 22 are no longer accepted on new CAPE declarations effective July 7, 2026.
See CBP CSMS #69127837.
That is the first likely explanation for the reader’s delay: CAPE accepted the Type 31 withdrawal, but the refund may still have been waiting on the associated warehouse entry.
For the broader timing framework, see Why Your CAPE Refund May Take Longer Than 90 Days.
For the filing rules that apply before acceptance, see our warehouse withdrawal CAPE filing guide. This article addresses what happens after a Type 31 withdrawal has already been accepted.
Do Not Confuse the Four Different Deadlines
The reader’s email referred to both the 80-day CAPE cutoff and a 90-day reliquidation period. Those numbers are related to different parts of the process.
| Time period | What it relates to |
|---|---|
| 80 days after liquidation | CAPE Phase 1 rejects an entry submitted more than 80 days after its liquidation date |
| 60–90 days after CAPE acceptance | CBP’s general refund expectation for qualifying entries outside the listed exception categories |
| 90 days after original liquidation notice | CBP’s voluntary reliquidation authority under 19 USC 1501 |
| 180 days after liquidation or reliquidation | The generally applicable protest period under 19 USC 1514(c)(3) |
For a Type 31 warehouse withdrawal, passing 90 days does not automatically mean the CAPE claim failed or that a protest must be filed. But it also does not mean the importer can safely ignore the liquidation date.
The protest clock must be monitored separately from the CAPE processing timeline.
What Could Be Holding Up the Refund?
The facts visible in ACE can point to several different causes.
The Associated Warehouse Entry Is Not Ready
CBP may still be waiting for all withdrawals against the warehouse entry to be completed. If the warehouse entry is not ready for liquidation, the Type 31 refund may remain pending even though CAPE accepted the withdrawal.
ACE Shows Only the Original Liquidation
The liquidation date in an ACE export may be the original liquidation date, not a later CAPE-related reliquidation. Check whether CBP created a new entry version, removed the IEEPA duty line, and issued a new liquidation or reliquidation event.
The Entry Is Under Additional Review
CAPE acceptance does not prevent CBP from selecting an entry for additional compliance review. If that happens, the refund may not move on the expected schedule.
The Refund Exists but Payment Has Not Arrived
If ACE shows a refund number or Treasury status, the problem may no longer be liquidation. It may instead involve an unpaid CBP debt offset, an incorrect Form 4811 recipient, incomplete ACH enrollment, or an ACH rejection.
The correct solution depends on which of these stages is actually stalled.
How to Resolve the Problem
1. Match the Type 31 Withdrawal to the Warehouse Entry
For every delayed entry, collect:
- CAPE claim number;
- Type 31 withdrawal entry number;
- associated warehouse entry number;
- importer of record number;
- filer code;
- CAPE acceptance date;
- original liquidation date;
- latest liquidation or reliquidation date;
- IEEPA duty paid; and
- current refund amount, number, date, and status.
The associated warehouse entry number is critical. Without it, the importer cannot determine whether CBP is waiting for the normal warehouse liquidation process to finish.
2. Confirm That the Right Entry Was Filed
Verify that the CAPE declaration contains the Type 31 withdrawal on which the IEEPA duty was paid.
If a filer submitted only a Type 21 or Type 22 warehouse entry between April 20 and July 6 without the corresponding withdrawal, CBP says that submission will not produce the refund. The filer must identify and submit the qualifying warehouse withdrawal, subject to the applicable CAPE validation rules.
Do not submit a duplicate Type 31 entry merely because the refund fields are blank. First determine whether the accepted claim is still pending, under review, or already linked to a refund record.
3. Follow the Entry Through ACE Reports
Use the reports in processing order:
| Report | What to check |
|---|---|
| ES-022 | Whether the individual Type 31 entry was accepted and whether an exception appears |
| ES-701 | Whether a liquidation or reliquidation event produced refund and interest information |
| REV-615 | CAPE-specific entry-level refund details and the refund number |
| REV-603 | Whether the refund was sent to Treasury, issued, diverted, or returned |
| REV-613 | Whether ACH payment was rejected |
If ES-022 shows Accepted but ES-701 and REV-615 remain blank, the entry likely has not reached refund creation. If REV-603 or REV-613 contains a status, investigate payment rather than reliquidation.
See our ACE CAPE refund monitoring guide for the complete report workflow.
4. Ask CBP Which Stage Is Pending
Once the entry relationship and ACE reports have been checked, send CBP a focused status inquiry. Technical CAPE questions can be directed to IEEPARefunds@cbp.dhs.gov.
Include enough information for CBP to identify both the withdrawal and the associated warehouse entry. Do not send only a screenshot showing CAPE Accepted.
The central question should be:
Is this Type 31 withdrawal waiting for the associated warehouse entry to become ready for liquidation, under additional review, pending reliquidation, or pending refund processing?
If the issue appears to sit with the processing Center, ask the broker to coordinate with the appropriate Center team as well.
5. Review the Protest Deadline Immediately
Do not wait for CBP’s email response before calculating the protest date.
In the reader’s example, the ACE record showed an original liquidation date of March 13, 2026. August 28, 2026 is approximately 168 days later. If March 13 is the controlling date, the 180-day point would be approximately September 9.
That does not mean a protest should automatically be filed. It means the importer should obtain entry-specific advice immediately.
An open or suspended protest is one of the conditions CBP checks during CAPE validation, so CAPE and protest strategy should be coordinated rather than treated as two unrelated filings. A licensed customs broker or trade lawyer should determine whether a protective protest is appropriate for the particular entry and how it affects the already accepted CAPE claim.
See How to File a Protest for IEEPA Tariff Refunds for the filing framework.
Sample Status Inquiry to CBP
Subject: Type 31 CAPE Claim Accepted — No Reliquidation After 90 Days
Dear CBP IEEPA Refunds Team,
We are requesting a status update for the following Type 31 warehouse withdrawal submitted under CAPE Phase 1:
- CAPE claim number: [claim number]
- Type 31 entry number: [entry number]
- Associated warehouse entry number: [warehouse entry number]
- Importer of record number: [IOR number]
- CAPE acceptance date: [date]
- Original liquidation date: [date]
ACE currently shows the claim as CAPE Accepted, but no reliquidation or refund amount, number, date, or status appears.
Please confirm whether the entry is waiting for the associated warehouse entry to become ready for liquidation, under additional review, pending reliquidation, or pending refund processing. Please also advise whether any additional information or action is required from the importer or filer.
Best regards,
[Name]
[Company]
Our Conclusion
A Type 31 entry that remains unreliquidated more than 90 days after CAPE acceptance is not automatically a failed claim. Warehouse withdrawals are outside CBP’s general 60-to-90-day processing expectation, and the refund may still depend on the associated warehouse entry.
The correct response is to:
- verify that the Type 31 withdrawal was the entry accepted by CAPE;
- identify the associated warehouse entry and its liquidation posture;
- trace the claim through the ACE reports;
- ask CBP which processing stage is pending; and
- obtain timely advice before the 180-day protest period expires.
This article is for educational purposes only. CAPE Portal Guide is not a law firm, customs broker, or government agency. Entry-specific liquidation, reliquidation, and protest decisions should be reviewed by qualified trade counsel or a licensed customs broker.
Primary Sources
- CBP CSMS #68340863 — CAPE Phase 1 validation, processing, warehouse timing, and protests
- CBP CSMS #69127837 — CAPE treatment of warehouse entries and warehouse withdrawals
- 19 USC § 1501 — Voluntary reliquidations by U.S. Customs and Border Protection
- 19 USC § 1514 — Protest against decisions of U.S. Customs and Border Protection
If your Type 31 withdrawal is accepted in CAPE but still has no reliquidation or refund record, request a confidential assessment so the entry relationship, ACE status, and protest deadline can be reviewed before the window closes.