What entries qualify for CAPE Phase 1?

The Phase 1 eligibility matrix

Per CBP CSMS guidance on the April 20, 2026 CAPE rollout, an entry qualifies if all of the following are true:

1. Entry was filed during the IEEPA window — 2025 effective date through February 20, 2026 liquidation ruling date
2. Duty included an IEEPA add-on line — visible in the entry summary detail
3. Entry is unliquidated, OR liquidated within 180 days and under active CF-19 protest
4. IOR is a US person or US-resident foreign IOR with active bond
5. No active CBP audit or fraud investigation on the entry

Entries that fail any criterion drop to Phase 2 (which CBP has not yet scoped) or require individual CF-19 protest.

Qualifying entry types

Type 01 — Consumption — Standard formal entry for goods intended for US commerce. The majority of CAPE filings will be Type 01.

Type 11 — Informal — Low-value entries under the informal entry threshold. CAPE accepts these but the refund per entry is typically small.

Type 23 — Foreign Trade Zone admissions — Qualify if IEEPA duty was paid on FTZ withdrawal. Zone status can complicate matching; your broker should batch these separately.

Type 06 — Warehouse withdrawal — Eligible if IEEPA duty was paid at withdrawal, not at original warehouse admission.

Entry types not in Phase 1

• Type 03 — Antidumping/Countervailing — ADD/CVD duties are outside CAPE scope
• Type 22 — Reconciliation — Handled through separate reconciliation close-out process
• Type 07 — Drawback — Different program under 19 USC 1313
• Type 09 — GSM (Government Specified Merchandise) — Limited to government importers

The unliquidated advantage

Unliquidated entries are the easiest CAPE claims:

• No CF-19 protest required
• CBP reliquidates at corrected rate automatically once claim is validated
• Refund flows through without a formal 19 USC 1514 filing
• Processing 45 to 75 days typical

To find your unliquidated entries, run the ACE Liquidation Report filtered for "unliquidated" status. See how to register in ACE.

The liquidated-within-180-days path

Liquidated entries require CF-19 protest within 180 days of the liquidation date (not the SCOTUS ruling date). Entry liquidated September 15, 2025? Protest deadline is approximately March 14, 2026 (180 days).

Miss the window and the liquidation becomes final under 19 USC 1514(c)(3). No refund path remains through CAPE. This is irreversible.

See when does an entry liquidate for how to find your exact liquidation date from the 7501 and the liquidation bulletin.

Entries outside the window

If your entry was filed before the IEEPA effective date or after February 20, 2026, it is not CAPE-eligible because there was no IEEPA duty on the entry to refund. Check the entry summary to confirm an IEEPA line item.

Phase 2 and beyond

CBP has hinted at a CAPE Phase 2 that would expand to liquidated-past-180-day entries via a special statutory refund authority. As of April 22, 2026, no rule has been published. Do not wait for Phase 2; file Phase 1 while the 180-day clock is running.

Documentation required per entry

For each CAPE-eligible entry, have on hand:

• CBP Form 7501 (Entry Summary) with IEEPA line visible
• Commercial invoice showing declared value
• Packing list and bill of lading
• Broker's working file showing HTSUS analysis
• Liquidation bulletin (if applicable)

Batch these into port-of-entry groups for efficient CAPE submission. See the IEEPA refund guide for batching strategy.

Calculate your tariff refund → /calculators/ieepa-refund

Related questions

Who qualifies as an importer? See who qualifies for a tariff refund.

When does an entry liquidate? Approximately 314 days after entry date. See liquidation date.

Are MPF and HMF refundable? MPF is generally not refundable on CAPE; HMF never is. See MPF and HMF.

Not legal advice. Customs business performed by licensed customs broker partners under 19 CFR 111.