IEEPA Refunds: What CAPE Phase 2 Means for Importers

U.S. Customs and Border Protection (CBP) has expanded its Consolidated Administration and Processing of Entries (CAPE) process for IEEPA tariff refunds, making additional entry types eligible for processing under Phase 2.

#ICYMI, during our recent webinar, Preparing for CAPE Phase 2, we walked through these changes, explained what they mean for importers, and demonstrated how BITE's ACE Analyzer helps compliance teams identify eligible entries in minutes rather than manually reviewing thousands of ACE records.

What Changed in CAPE Phase 2?

When CAPE first launched, it focused on relatively straightforward refund scenarios, including unliquidated entries and recently liquidated entries still within CBP's 80-day liquidation window.

Phase 2 expands CAPE to certain entries that were previously outside the program's scope. Specifically, some entries flagged for reconciliation where no reconciliation entry has been filed yet, that are still unliquidated or within 80 days of liquidation are now eligible. For importers, the practical impact is not simply a larger number of potential refund claims, but a larger population of ACE entries that should be evaluated for eligibility.

Finding Eligible Entries Isn't as Simple as Filtering for Chapter 99

While CAPE Phase 2 expands refund opportunities, it also increases the complexity of identifying eligible claims.

Compliance teams may need to review thousands of ACE entry records to determine whether an entry is ready for a CAPE declaration. Simply filtering for Chapter 99 codes is rarely enough. Reconciliation activity, mixed Chapter 99 provisions, anti-dumping and countervailing duties (AD/CVD), post-entry corrections, protests, and other entry-specific conditions can all affect whether an entry is immediately claimable or requires additional review.

For organizations managing large import volumes, manually reviewing spreadsheets is both time-consuming and difficult to scale. The challenge is no longer just identifying entries that paid IEEPA duties, it is determining which entries are ready to file and which require further validation before submitting a refund claim.

How BITE's ACE Analyzer Supports CAPE Phase 2

As part of our recent product update, we've expanded our ACE Analyzer to support the new CAPE Phase 2 workflow.

The latest release introduces:

A dedicated CAPE Phase 2 eligibility report alongside existing Phase 1 reporting.
Automatic Claimable vs. Needs Review categorization for every entry.
Review explanations that identify why an entry requires additional validation, including:
Mixed refundable and non-refundable Chapter 99 codes
Anti-dumping entries tied to reconciliation
Post-entry corrections, protests, or reliquidations
Zero-dollar or unusually large refund amounts
Duty calculations that differ from expected values
Entry Roll-Up reporting that summarizes claimable entries, reconciliation activity, duplicate lines, and review totals.
CSV exports and printable findings reports for documentation, collaboration, and audit support.

Importantly, "Needs Review" does not mean an entry is ineligible. It simply highlights where a compliance professional should verify supporting information before submitting a CAPE declaration.

Preparing for Phase 2

If your organization paid IEEPA duties, now is a good time to prepare by:

Identifying potentially affected ACE entries.
Reviewing reconciliation status and post-entry activity.
Confirming ACH information is current in ACE for refund processing.
Coordinating responsibilities between internal compliance teams and customs brokers.
Prioritizing entries that appear ready to file while setting aside those requiring additional review.

Organizations that prepare now will be in a much stronger position as additional CAPE refund opportunities become available.

From ACE Data to Refund Strategy

CAPE Phase 2 expands the population of entries that may qualify for IEEPA refunds, but it also makes the review process more complex. Importers must look beyond Chapter 99 duties alone to evaluate reconciliation activity, post-entry changes, and other factors that can affect claim readiness.

Establishing a structured review process now can help compliance teams identify eligible entries more efficiently, prioritize claims that are ready to file, and maintain the documentation needed to support refund requests.

BITE's ACE Analyzer automates much of this review by analyzing ACE data, identifying potentially eligible entries, highlighting records that require additional validation, and generating audit-ready reports. Rather than relying on manual spreadsheet reviews, compliance teams can quickly focus their efforts where they matter most.

If you missed our recent webinar, Preparing for CAPE Phase 2, or would like to see the updated ACE Analyzer in action, contact us for a personalized demonstration to learn how BITE helps importers identify, evaluate, and prioritize IEEPA refund opportunities with confidence.