CAPE Phase 1: What's Covered, What's Excluded, and How to Prepare

CBP’s CAPE (Consolidated Administration and Processing of Entries) system launches April 20, 2026 with Phase 1. Here’s exactly what Phase 1 covers, how it works, and what to do if your entries aren’t eligible yet.

What Phase 1 Covers

Phase 1 is limited to two categories of entries:

1. Unliquidated Entries

Entries where you’ve paid IEEPA duties but CBP has not yet liquidated the entry. These are the simplest to process — once a CAPE declaration is accepted:

The entries will be set to liquidate 45 days from the declaration acceptance date
IEEPA duties will be removed during this liquidation

2. Recently Liquidated Entries (Within ~80 Days)

Entries that CBP has liquidated within approximately 80 days of your CAPE filing. For these entries:

CBP will reliquidate the next business day after processing
The reliquidation will remove IEEPA duties and trigger a refund

What Phase 1 Excludes

The following entry types are not eligible for Phase 1:

Entries with pending protests under 19 USC § 1514
Entries subject to AD/CVD (Anti-Dumping/Countervailing Duty) orders
Entries associated with drawback claims
Entries in reconciliation
Warehouse entries
Entries with extended, suspended, or “under review” liquidation status

CBP has indicated these categories will be addressed in future CAPE phases.

How the Filing Process Works

Step 1: Prepare Your Entry List

Identify entries with IEEPA Chapter 99 duties (HTS 9903.01.25–9903.01.70)
Format as CSV: one 11-digit entry number per row
Maximum 9,999 entries per declaration
No duplicates within or across declarations

Step 2: File Your Declaration

Log into ACE Portal → CAPE application
The importer of record or an authorized customs broker can file
Upload your CSV file
Sign the compliance certification
Submit — declarations cannot be amended or withdrawn once submitted

Step 3: Wait for Processing

CBP reviews the declaration and adjusts covered entries
Unliquidated entries: set to liquidate in 45 days
Liquidated entries: reliquidated next business day

Step 4: Receive Your Refund

Individual entry refunds are consolidated by importer of record (or designated party) and liquidation date
Disbursed as one lump sum via ACH direct deposit
Expect 60-90 days from declaration acceptance for valid refunds
This includes 45 days for CBP review plus additional processing time

What If Your Entries Don’t Qualify for Phase 1?

If your entries fall outside Phase 1’s scope, here’s what to do:

File protests: If your entries are liquidating now, protest within 180 days
Monitor future phases: CBP plans to expand CAPE eligibility
Consult a trade attorney: For finally liquidated entries, a CIT lawsuit may be necessary
Stay informed: Subscribe to CBP’s CSMS notifications for updates

Key Numbers to Remember

Metric	Value
Max entries per declaration	9,999
Liquidation timeline (unliquidated entries)	45 days from acceptance
Reliquidation timeline (liquidated entries)	Next business day
Refund processing time	60-90 days
Protest deadline	180 days from liquidation

Ready to file? Read our complete Step-by-Step Guide or check your eligibility. Need professional help? Get a free assessment.