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On June 23, 2026, CBP via CSMS 69035485 issued guidance explaining which reconciliation-flagged entries will be eligible for the next phase of the Consolidated Administration and Processing of Entries (CAPE) tariff refund tool, launching June 29, 2026.

CBP said the new phase (CAPE Phase 2) will accept only entries flagged for reconciliation when the subsequent reconciliation entry has not yet been filed with Customs. In contrast, entries flagged for reconciliation with a reconciliation entry already on file will be handled in a future CAPE phase and will not be included in the June 29 (CAPE Phase 2) rollout. In other words, CAPE will accept reconciliation-flagged entry types 01, 02, and 06, as long as the related reconciliation entry (type 09) has not been submitted. As with CAPE Phase 1 CBP also limited eligibility to unliquidated entries and entries within 80 days of liquidation.

CBP further clarified that once a reconciliation-flagged entry is accepted on a CAPE declaration, the trade may proceed to file the reconciliation entry. CAPE will remove IEEPA duties from the flagged entries before the reconciliation filing, separating the refund activity from the reconciliation calculations. After the reconciliation entry is filed, CBP said it will assume all related CAPE declarations associated with the reconciled entries were filed and accepted. Once a reconciliation entry is filed, the underlying entries will not be eligible to be filed on a CAPE Declaration in Cape Phase 2. 

Finally, CBP cautioned that if a reconciliation filing deadline is less than 30 days away, filers should prioritize submitting the reconciliation entry. All filing and processing requirements from CAPE’s first phase (CAPE Phase 1) remain in effect.

The Husch Blackwell International Trade and Supply Chain team will continue to monitor this and provide updates as they become available. If you have any questions or concerns, please contact your Husch Blackwell attorney.

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Photo of Nithya Nagarajan Nithya Nagarajan

Nithya’s extensive background in U.S. trade issues spans 25 years and includes various roles in a number of federal government agencies, including the Department of Commerce Department of Justice, and the U.S. Court of International Trade. She assists clients with administrative and regulatory…

Nithya’s extensive background in U.S. trade issues spans 25 years and includes various roles in a number of federal government agencies, including the Department of Commerce Department of Justice, and the U.S. Court of International Trade. She assists clients with administrative and regulatory actions before the Department of Commerce, International Trade Commission and U.S. Customs and Border Protection (CBP) and defends clients in appeals before the Court of International Trade, Court of Appeals for the Federal Circuit, NAFTA panels and the World Trade Organization. In addition to her body of U.S. experience, Nithya is also well-versed in international trade issues in China and India.

Photo of Robert Stang Robert Stang

Bob focuses his practice on customs and international trade law. He brings 30 years of experience to a wide range of issues that affect inbound and outbound goods, including tariff classification, valuation, country of origin marking matters, free trade agreements, and special trade…

Bob focuses his practice on customs and international trade law. He brings 30 years of experience to a wide range of issues that affect inbound and outbound goods, including tariff classification, valuation, country of origin marking matters, free trade agreements, and special trade programs. He also has extensive customs compliance experience and regularly assists importers facing U.S. Customs and Border Protection (CBP) audits, penalties, seizures, redelivery notices and other agency enforcement activities. Bob works with importers and exporters proactively to achieve cost savings and structure programs that meet CBP “reasonable care” requirements. He also handles supply chain security issues, including Customs-Trade Partnership Against Terrorism (C-TPAT) enrollment, verification and annual reviews.

Photo of Dimitri Zografi Dimitri Zografi

Dimitri assists clients with real estate matters. He focuses on the development and tax side of real estate. Dimitri is known for his hard work, dedication, and genuine passion for his practice area, and he uses his background in economics and mathematics, his

Dimitri assists clients with real estate matters. He focuses on the development and tax side of real estate. Dimitri is known for his hard work, dedication, and genuine passion for his practice area, and he uses his background in economics and mathematics, his legal training, and his past experiences to provide the best possible service.