CAPE Phase II Is Live: Most IEEPA Duties Are Now Refund-Eligible — Here’s How to Claim Yours
KEY TAKEAWAYS
- As of June 29, 2026, CBP’s CAPE system reached Phase II — enhanced processing for reconciliation-flagged entries, making the large majority of IEEPA duties eligible for refund.
- Refunds are not automatic for every entry type. Eligibility, filing method, and ACH enrollment all matter — and finally, liquidated entries are treated differently depending on whether you filed a CIT lawsuit.
- The window rewards speed and documentation. Importers who reconcile their IEEPA-dutied entries now will recover capital sooner; those who wait risk falling into later, slower phases.
Tariff Refunds – a Moving Target
If your business paid duties imposed under the International Emergency Economic Powers Act (IEEPA), you have likely been watching a moving target: litigation over whether those duties were lawfully collected, a refund mechanism built in phases, and shifting guidance on which entries qualify and when. The result is paralysis — many importers know money may be owed back to them, but cannot tell whether, how, or when to claim it.
That uncertainty has a real cost. Every month, a refund-eligible entry that sits unaddressed, working capital tied up at CBP rather than in your business. And because the refund framework is being rolled out in stages, the entries you can act on today are not the same as the ones you will be able to act on next month — sequencing matters.
