CBP Announces New CAPE Enhancement Effective June 29, 2026

U.S. Customs and Border Protection (CBP) has announced an important enhancement to the Consolidated Administration and Processing of Entries (CAPE) program that will impact importers seeking refunds of International Emergency Economic Powers Act (IEEPA) duties.

Effective June 29, 2026, CBP will expand CAPE functionality to allow certain entries flagged for reconciliation to be included in CAPE refund declarations, even when the corresponding reconciliation entry has not yet been filed.

This update builds upon the initial CAPE deployment launched on April 20, 2026, and provides additional flexibility for importers pursuing IEEPA duty refunds.

What Is Changing?

Under the June 29 enhancement, CAPE will now accept:

• Entry Types 01, 02, and 06 that have been flagged for reconciliation;
• Entries where the reconciliation entry (Type 09) has not yet been filed;
• Entries that remain unliquidated or are within 80 days of liquidation.

Once these entries are accepted through CAPE, importers may proceed with filing the reconciliation entry separately.

Importantly, CAPE will remove the applicable IEEPA duties from the underlying entries before the reconciliation is filed, effectively separating the IEEPA refund process from the reconciliation calculations.

How Does This Impact Reconciliation Filings?

CBP has clarified that once a reconciliation entry is filed, it will assume that all associated CAPE declarations have already been submitted and accepted.

As a result:

• Entries that have already been reconciled will not be eligible for CAPE filing under this deployment.
• Importers should carefully evaluate timing when both CAPE refund opportunities and reconciliation deadlines are approaching.
• If a reconciliation filing deadline is nearing expiration, CBP recommends prioritizing the reconciliation filing to maintain compliance.

What Is Not Included Yet?

At this time, the June 29 deployment does not include:

• Entries flagged for reconciliation where the reconciliation entry has already been filed.

CBP has indicated that support for these scenarios is expected in a future phase of CAPE development.

Additional guidance and filing requirements will be communicated through future Cargo Systems Messaging Service (CSMS) announcements as new functionality becomes available.

Key Considerations for Importers

Importers and customs compliance teams should consider the following:

✔ Review pending IEEPA refund opportunities involving reconciled and unreconciled entries.

✔ Identify entries flagged for reconciliation that remain unliquidated or are within 80 days of liquidation.

✔ Coordinate closely with customs brokers and trade compliance teams before filing reconciliation entries.

✔ Monitor upcoming CAPE enhancements and CBP guidance as additional functionality is expected in future phases.

How J.O. Alvarez Can Help

The J.O. Alvarez Compliance Team is available to assist importers in evaluating CAPE eligibility, reviewing refund opportunities, and navigating reconciliation-related requirements to help ensure compliance while maximizing potential duty recovery opportunities.

For questions regarding CAPE filings, IEEPA refunds, or reconciliation procedures, please contact the J.O. Alvarez Compliance Team.

Compliance Disclaimer

This article is provided for informational purposes only and reflects our understanding of CBP guidance as of June 2026. Importers should review the applicable CBP regulations, CSMS messages, and filing requirements and consult with their customs broker or trade advisor regarding specific transactions. Final determinations regarding eligibility, refunds, liquidation status, and reconciliation requirements remain subject to review and determination by U.S. Customs and Border Protection.