On June 23, 2026, U.S. Customs and Border Protection (“CBP”) published Cargo Systems Messaging Service (“CSMS”) #69035485, confirming that Phase 2 of the process for refunding duties paid by importers of record under the International Emergency Economic Powers Act (“IEEPA”) will be deployed in the Automated Commercial Environment (“ACE”) Portal on June 29, 2026. CBP unveiled the refund process, known as the Consolidated Administration and Processing of Entries (“CAPE”), in a March 12, 2026 declaration to the U.S. Court of International Trade (“CIT”), confirming that the IEEPA tariff refund process would be implemented in multiple phases (see Update of March 13, 2026).

Consistent with CBP’s June 4, 2026 CIT filing, Phase 2 of the CAPE will cover entries flagged for reconciliation (entry types 01, 02, and 06) where a corresponding reconciliation entry (entry type 09) has not yet been filed (see Update of June 15, 2026). By contrast, entries flagged for reconciliation where a reconciliation entry is already on file “will be included in a future phase of CAPE development.”

The scope of Phase 2 is further limited to unliquidated entries and entries within 80 days of liquidation, consistent with Phase 1 of the CAPE. Introduced in a March 31, 2026 declaration to the CIT, Phase 1 of the CAPE refunds IEEPA tariffs collected on unliquidated entries and entries no more than 80 days past liquidation (see Update of April 3, 2026).

As stated in the CSMS message, Phase 2 will also operate concurrently with Phase 1, which has been in effect since April 20, 2026 via the ACE Portal (see Update of April 10, 2026). The filing requirements and processing procedures applicable to Phase 2 will be identical to those used in Phase 1.

Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.

Photo of David M. Schwartz David M. Schwartz

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping…

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.