CAPE Phase 1 (opened April 20, 2026) covers most consumption entries between April 5, 2025 and February 24, 2026. Phase 2 (anticipated 2026-2027) is expected to cover edge cases – partially-liquidated entries, reconciliation entries, FTZ admissions, and complex entry types not handled in Phase 1. Phase 1 covers approximately $127B of the $166B collected.
This guide covers ieepa refund phase 1 vs phase 2 – scope and differences for SMB importers. Each section walks through the practical implications and the documentation required.
For background, see /section-122-tariff-guide/ and /ieepa-refund-guide/.
What Phase 1 covers
Standard Type 01 consumption entries between April 5, 2025 and February 24, 2026 with clearly attributable IEEPA duty. Most SMB importer filings fit Phase 1.
What Phase 1 does not cover
Reconciliation entries with IEEPA component spread across multiple periods. FTZ admissions in NPF status with partial IEEPA exposure. Partially-liquidated entries where IEEPA portion is unclear. These are expected to be Phase 2.
Anticipated Phase 2 timeline
CBP has not published a firm Phase 2 timeline. Industry expectation is Q3-Q4 2026 with ongoing technical guidance.
What to do for Phase 2 cases now
Continue to file Phase 1 claims for clearly eligible entries. Hold Phase 2 candidates pending guidance. Maintain documentation; do not let the 180-day protest window lapse on liquidated entries while waiting for Phase 2.
Frequently asked questions
How does this affect my forward planning?
Build the relevant scenario into your 2026 budget. We can run a fixed-fee scenario model for $4,500-$8,500 covering your specific exposure.
What documentation supports this?
Standard CBP Form 7501 entry summary, supplier-provided Certificates of Origin where USMCA-relevant, and origin documentation for substantial transformation claims. We review documentation as part of typical engagements.
Are there court cases I should track?
Yes – see /ieepa-litigation-cit-watch/ for current case status.
When should I engage a consultant?
For exposure above $50,000 annual or filings above $50,000 recoverable. Below those thresholds, self-management with our written guides usually works.
How do I get started?
Book a 15-minute scoping call. We confirm fit and scope before any engagement letter.
Get started
Book a 15-minute scoping call to discuss your situation.