CBP has issued several updates since CAPE Phase 1 launched on April 20. Here’s where things stand:

• $35.46 billion in estimated IEEPA duty refunds and interest have been calculated for liquidated and reliquidated entries
• 15.1 million entries have passed CAPE file and entry-level validations and been accepted for IEEPA duty removal
• 8.3 million entries have been liquidated or reliquidated with IEEPA duties removed
• ACH refund payments began issuing as of May 12, 2026
• On May 15, CBP issued a Trade Bulletin with additional CAPE filing resources and guidance for importers and brokers

Common issues flagged by filers so far: HTS relationship/sequence mismatches, ACE access problems (password resets, username errors), and confusion over which IOR is authorized to submit a CAPE Declaration. If any of these apply to your entries, contact us before resubmitting — a rejected Declaration can complicate your timeline.

Phase 1 is still active. If you haven’t filed yet, the window for unliquidated entries and entries within 80 days of liquidation is open. Entries approaching that 80-day threshold should be prioritized now.

CBP filed its latest declaration with the Court of International Trade today May 26th, 2026. 

The latest numbers from CBP’s court filing:

• 157,402 CAPE declarations submitted since the April 20 launch
• 108,760 declarations passed file validations
• 15,852,806 entries accepted for IEEPA duty removal through CAPE
• 8,515,477 entries liquidated or reliquidated without IEEPA duties
• Approximately $85 billion in potential and certified refunds accepted for processing in CAPE
• $20.6 billion in refunds certified and sent to Treasury for disbursement
• 4,185 consolidated refunds not yet transmitted to Treasury because ACH account information has not been provided

An important correction to a previously reported figure:

CBP’s May 26 declaration corrects the $35.46 billion figure cited in the May 12 filing. That figure was overstated by approximately $10 billion due to an inadvertent error in the data query used to calculate it. The correct figure for anticipated duty refunds with interest for liquidated and reliquidated entries as of May 11 was approximately $25.46 billion. This was not an error in CAPE processing or refunds — it was a reporting error in CBP’s internal data query.

Why the top-line number is now larger.

The $85 billion figure represents the full pool of potential and certified refunds accepted into CAPE — a significantly larger number than the liquidated-entries-only figure previously reported. $20.6 billion of that has already been certified and sent to Treasury. The remainder is being reviewed and finalized through CAPE’s Review and Liquidation/Reliquidation component.

Why declarations are failing — CBP identified the three primary causes:

• Importer of record or filer mismatches on CAPE declarations
• Entry number validation errors (incorrect length or entry number does not exist)
• CSV file not formatted in alignment with the ACE portal template

If any of these apply to your entries, contact us before resubmitting. A rejected declaration can complicate your timeline.

The ACH problem is getting worse, not better.

4,185 consolidated refunds are now frozen because ACH account information has not been provided — more than double the 1,880 reported on May 12. If your ACH Refunds enrollment is not active and accurate in ACE, your refund cannot move to Treasury. CBP will not send a paper check. This needs to be resolved now.

Phase 1 is still active.

The window for unliquidated entries and entries within 80 days of liquidation remains open. Entries approaching that 80-day threshold should be prioritized immediately.

CAPE Phase 2 Is Live

CBP officially deployed Phase 2 of CAPE within ACE on June 29, 2026, according to a CSMS message published that morning. Phase 2 expands the program to allow entries flagged for reconciliation (types 01, 02, and 06) to be filed on a CAPE declaration for the first time. Some limitations apply. The reconciliation-flagged entry must be unliquidated, or if liquidated, not more than 80 days past the liquidation date, following the same eligibility guidelines established in Phase 1. Importantly, the reconciliation entry (type 09) must not be filed prior to the CAPE declaration.

Ahead of the deployment, on June 23 CBP issued CSMS 69035485 with detailed filing guidance for Phase 2.

The most important takeaway for importers is one of sequencing: CBP is asking the trade to prioritize reconciliation filings over CAPE declarations where a deadline is near.

As the message states, if the reconciliation filing deadline is close to expiring, for example less than 30 days out, the trade will need to prioritize filing the reconciliation first. Entries flagged for reconciliation that already have a reconciliation entry on file will be addressed in a future phase of CAPE development rather than in Phase 2.

All Phase 1 requirements remain in effect.

If you have reconciliation-flagged entries, the practical order of operations matters more than ever: confirm your entry is within the eligibility window, make sure no type 09 reconciliation entry has already been filed against it, and weigh any upcoming reconciliation deadline before you submit a CAPE declaration. If you are unsure how these rules apply to your specific entries, this is a good moment to review your data carefully or speak with your customs broker or attorney before filing.