ACA's Update on CBP's CAPE System
Key Highlights
- The CAPE system is being built within CBP's ACE platform to process IEEPA tariff refunds more efficiently.
- Phase 1 is scheduled to start accepting eligible entries by April 20, 2026, covering approximately 63% of affected entries.
- Certain entries, such as liquidated, protested, or drawback claims, are excluded from Phase 1 and will be addressed in future phases.
- CBP estimates a review and reliquidation period of up to 45 days after accepting a CAPE declaration.
The Auto Care Association (ACA) offers an update on U.S. Customs and Border Protection's (CBP) scope and timeline of Phase 1 of its new CAPE system.
The CAPE system is a mechanism being built within its Automated Commercial Environment (ACE) to process refunds of IEEPA tariffs that the court has ordered returned to importers.
The four components are currently between 60% and 85% complete. CBP plans to meet the April 20, 2026, deadline to begin accepting CAPE Declarations or Phase 1-eligible entries.
Phase 1 will process entries that are either unliquidated or still within the 90-day voluntary reliquidation window under 19 U.S.C. § 1501. CBP estimates this covers roughly 63 percent of affected entries.
CAPE will also accept:
- Entries with a liquidation status of Suspended, Extended, or Under Review
- Warehouse and warehouse withdrawal entries
Refunds for those entries will be issued in the normal course at liquidation, not immediately.
The following categories of entries are excluded from Phase 1:
- Finally, liquidated entries (CBP intends to address these in a future phase)
- Entries flagged for reconciliation
- Entries designated on a drawback claim
- Entries covered by an open protest
- Entries not filed in ACE or without a liquidation status in ACE
- AD/CVD entries for which Commerce has issued liquidation instructions pending under 19 U.S.C. § 1504(d)
- Entries outside the 90-day voluntary reliquidation window
CBP has up to 45 days from accepting a CAPE Declaration to review and reliquidate the identified entries, absent any compliance concerns requiring additional review.
For more information regarding CIT's Phase 1 of its new CAPE system, click here.