$100 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 2.2 million reconciliation-flagged entries successfully filed by July 31.
Last official update reviewed
CBP's August 4 Lord Declaration reports $128.68 billion accepted for CAPE processing and approximately $100 billion completed and sent to Treasury as of July 31. 19,726 refunds (about $1.6 billion) remain held because importers have not provided ACH information. The August 5 CIT order confirms the July 17 reliquidation order has been entered in more than 3,700 IEEPA cases. CBP must file its next CAPE progress report by August 25, with a settlement conference on August 26.
Most important limitation
Judge Eaton's July 17 order directs CBP to reliquidate finally liquidated entries only for plaintiffs in the approximately 3,700 IEEPA cases assigned to the court. Importers who did not file a CIT lawsuit are not covered by this order. The government filed its opposition to the Freestyle World class-certification motion on July 28, so certification is contested and not guaranteed. File protective protests where the window is open and seek trade-counsel review for material finally liquidated 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 31, 2026, CBP had accepted approximately $128.68 billion in potential and certified refunds for CAPE processing and sent approximately $100 billion to the Treasury for disbursement. Average turnaround remains ~18 days for clean entries.
Source: CBP Lord Declaration, CIT (August 4, 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 August 4 declaration confirms 19,726 approved refunds (about $1.6 billion) remain stuck because importers have not provided valid ACH banking information — check yours before you file.
Source: CBP Lord Declaration, CIT (August 4, 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.
Euro-Notions dismissed its lead CIT IEEPA refund case; Freestyle World takes over with a class-certification motion pending. Pipeline now $121.75B.
Read article →CBP's August 4 progress report shows $128.68B accepted and $100B sent to Treasury, but 19,726 refunds remain held for missing ACH. See what it means for your refund.
Read article →Judge Eaton ordered CBP to reliquidate finally liquidated entries for 3,700+ IEEPA plaintiffs. Learn what the order requires and how to submit your CAPE declaration.
Read article →CBP expects CAPE Phase 3 technology by late July 2026, but refunds for non-litigants remain disputed. Compare CAPE, protest, and CIT options.
Read article →