How to File Warehouse Withdrawal Entries for IEEPA Refunds in CAPE

CBP’s July 2026 warehouse guidance changes the filing target for importers using bonded warehouse entries. The key distinction is simple: do not file the warehouse entry if the IEEPA duty was paid on the withdrawal. File the warehouse withdrawal entry instead.

This guide explains which entry types now belong in CAPE, how to clean up Type 21 or Type 22 filings that were submitted before the rule changed, and why protest deadlines still need to be tracked while warehouse refunds wait for liquidation.

What CBP Changed on July 2, 2026

CBP issued CSMS #69127837 on July 2, 2026 to clarify how bonded warehouse entries and warehouse withdrawals should be handled in CAPE.

The operational rule is now:

• Entry Types 21 and 22: effective July 7, 2026, these warehouse entries are no longer accepted on CAPE Declarations.
• Entry Types 31, 32, 34, and 38: these warehouse withdrawals continue to be accepted on CAPE Declarations because the IEEPA duties were paid on the withdrawals.
• Existing Type 21 or Type 22 submissions: if accepted from April 20 through July 6 without the corresponding warehouse withdrawal, they will not be liquidated or reliquidated with an IEEPA refund.

Source: CBP CSMS #69127837, “UPDATE - Consolidated Administration and Processing of Entries (CAPE) for IEEPA Refunds - Warehouse Entries,” sent July 2, 2026.

Why Warehouse Withdrawals Are Different

Bonded warehouse accounting is not the same as ordinary consumption-entry accounting. Merchandise can enter a bonded warehouse before the duty payment event. The IEEPA duty is generally assessed when merchandise is withdrawn for consumption, which means the recoverable duty sits on the withdrawal entry rather than on the warehouse admission itself.

That is why the CAPE filing target is the withdrawal. For many importers, the practical data pull is:

1. Identify all bonded warehouse activity tied to the IEEPA tariff period.
2. Separate warehouse entries from warehouse withdrawals.
3. Pull the withdrawal entry numbers where HTS Chapter 99 IEEPA lines were present.
4. Confirm the withdrawal entries are in ACE and have an eligible liquidation posture.
5. File the withdrawal entries through CAPE, not the underlying warehouse entries.

If your team also uses Foreign Trade Zones, keep that analysis separate. FTZ withdrawals and bonded warehouse withdrawals are related duty-deferral concepts, but CBP’s July 2 message is specifically about warehouse entries and warehouse withdrawals. See the broader FTZ and bonded warehouse IEEPA refund guide for the strategy layer.

CAPE Filing Table for Warehouse Entry Types

Use this table before building your CSV:

CBP says warehouse withdrawals submitted through CAPE can result in approved IEEPA refunds, but those refunds are processed upon liquidation or reliquidation of the associated warehouse entry. That makes warehouse refunds more timing-sensitive than ordinary consumption-entry refunds.

If You Filed Type 21 or Type 22 Before July 7

CBP gave a specific cleanup rule for filings made before the July 7 change. If a warehouse Entry Type 21 or 22 was accepted on a CAPE Declaration from April 20, 2026 through July 6, 2026 without the corresponding warehouse withdrawal, CBP says it will not be liquidated or reliquidated with a refund of IEEPA duties.

The fix is to submit another CAPE Declaration containing the warehouse withdrawals on which IEEPA duties were paid.

For cleanup, build a worksheet with:

• the original CAPE Declaration number;
• the Type 21 or Type 22 warehouse entry that was submitted;
• every related withdrawal entry number;
• the withdrawal entry type;
• the IEEPA Chapter 99 line, usually in the 9903.01.25 through 9903.01.70 range;
• the IEEPA duty paid on the withdrawal;
• current liquidation status; and
• any protest deadline tied to the withdrawal.

Then file a clean replacement CAPE Declaration with only the eligible warehouse withdrawal entries. Do not resubmit accepted entries that already produced a refund record. Use the CAPE validation error guide and the CAPE CSV preparation guide before uploading.

Watch Liquidation Timing and Protest Deadlines

Warehouse withdrawal refunds may wait on the liquidation or reliquidation of the associated warehouse entry. CBP also says normal warehouse liquidation continues after all withdrawals have been made and the warehouse entries are ready for liquidation.

That timing creates two parallel calendars:

• CAPE calendar: Has the withdrawal entry been accepted, validated, and queued for refund processing?
• Protest calendar: Has the withdrawal or related entry liquidated, starting the 180-day protest deadline under 19 USC 1514?

Do not let the CAPE calendar hide the protest calendar. If a withdrawal liquidates and the refund posture remains uncertain, consider a protective protest while the window is open. The IEEPA protest filing guide and the CAPE, protest, or CIT decision framework explain how to preserve rights without assuming CAPE will solve every entry posture.

What to Pull From ACE Before Filing

Before you file warehouse withdrawals through CAPE, ask your broker or ACE Trade Account Owner for:

• a list of all warehouse withdrawals during the IEEPA tariff period;
• entry type and entry number for each withdrawal;
• the related warehouse entry number;
• HTS Chapter 99 IEEPA duty lines;
• liquidation status and liquidation date;
• any open protest indicator;
• any ACH refund recipient issue for the importer of record or Form 4811 notify party; and
• the broker/filer code tied to the withdrawal.

After filing, monitor the same refund lifecycle used for ordinary CAPE claims: ES-022 for entry/refund linkage, REV-603 for Treasury status, REV-613 for ACH rejection, and REV-615 for refund detail. The ACE reports monitoring guide explains how those reports fit together.

Common Filing Mistakes

Mistake 1: Filing the warehouse admission instead of the withdrawal. After July 7, Type 21 and 22 warehouse entries should not be included in a new CAPE Declaration.

Mistake 2: Assuming a prior accepted Type 21 or 22 filing will pay out. CBP says those April 20 through July 6 submissions will not generate IEEPA refunds unless the corresponding warehouse withdrawals are filed.

Mistake 3: Treating all duty-deferral entries as one bucket. Warehouse withdrawals, FTZ withdrawals, reconciliation flags, drawback claims, and AD/CVD entries can each have different CAPE treatment.

Mistake 4: Waiting for liquidation without preserving protest rights. CAPE does not pause the 180-day protest clock. Calendar it separately.

Mistake 5: Forgetting ACH. A correct warehouse withdrawal filing can still stall if the refund recipient lacks valid ACH information. See the ACH enrollment guide.

Source Notes

Primary source: CBP CSMS #69127837, July 2, 2026.

Related official source: CBP IEEPA Duty Refunds page, last modified July 6, 2026.

CAPE Portal Guide is not a law firm, customs broker, or government agency. Warehouse entries can involve statutory deadlines and entry-specific liquidation issues. For material claims, coordinate with a licensed customs broker and trade counsel.

If your bonded warehouse withdrawals include material IEEPA duty exposure, request a free assessment and we will connect you with vetted trade counsel who can review the withdrawal list, protest clock, and CAPE filing sequence.