Not an April Fools’ Day Post: CBP’s CAPE Refund System Just Got a Lot More Real

This is not an April Fools’ Day post.

CBP provided a significant progress update on CAPE to the U.S. Court of International Trade on March 30. And for the first time, importers have enough operational detail to make real decisions about refund strategy, entry prioritization, and internal readiness.

The headline numbers matter. But the details underneath them matter more.

Where CAPE Stands Right Now

As of March 30, the CAPE claim portal is 85% complete and actively in testing. That is a meaningful jump from the 70% figure CBP reported earlier this month.

Once the portal opens, CBP has indicated it can take up to 45 days from acceptance of a CAPE declaration to review and liquidate the entry. That means the refund timeline is not instant, but it is defined. And that definition gives finance teams, customs teams, and brokers something they have not had until now: a planning window.

What Phase 1 Covers

CBP has also clarified the scope of Phase 1, and this is where importers need to pay close attention.

Phase 1 will be limited to entries that have not yet been liquidated or are within the 90-day protest period following liquidation. CBP will also accept CAPE requests for liquidated entries, but only if they are no more than 80 days past the liquidation date.

That Phase 1 scope is expected to cover approximately 63% of impacted entries. That is a significant share, but it also means roughly 37% of affected entries will need to wait for a subsequent phase.

CBP intends to expand CAPE to process final liquidated entries in a later phase. But no timeline for that expansion has been given yet.

What Gets More Complicated

CBP has now prepared to accept CAPE declarations for more complex entry types, including entries that are suspended, extended, or under liquidation review. That is progress. But there is an important distinction: approved refunds for those entries will not process until the normal liquidation cycle is completed.

That means a CAPE declaration can be accepted and approved in the system, but the actual refund disbursement may still be held up by standard liquidation timing.

Here is where specific entry types stand:

Antidumping and countervailing duty (AD/CVD) entries are included in CAPE if liquidation is suspended pending instructions from the U.S. Department of Commerce. However, CBP will not liquidate or process refunds on those entries until the suspension is lifted per Commerce Department direction.

Warehouse and warehouse withdrawal entries will not liquidate with approved refunds until all withdrawals have been made and the warehouse entry is ready for liquidation.

Entries tied to reconciliation, drawback claims, open protests, or AD/CVD entries pending liquidation in accordance with Commerce Department direction remain in a pending refund status. Those will not move through CAPE until those processes are resolved.

For importers with a mixed entry population, this is important. Some of your entries may be straightforward Phase 1 candidates. Others may require a different timeline, a different strategy, or simply a different set of expectations internally.

Why This Matters Now

The CAPE system is no longer theoretical. It is in testing. The processing rules are taking shape. And the 45-day review window means the distance between portal launch and first refunds is measurable.

But preparation is still the variable that separates fast movers from companies that stall in the queue.

If your entry data is clean, your ACE Portal access is confirmed, your ACH refund setup is current, and your team has already separated Phase 1 candidates from more complex entries, you are in position to move when CAPE opens.

If you have not done that work yet, the window is still open. But it is getting shorter.

What Importers and Brokers Should Do Now

1. Review the March 30 CBP filing and assess how your entry population maps to Phase 1 eligibility.
2. Confirm ACE Portal access and ACH refund enrollment are current and complete.
3. Build or update your working list of affected entries with liquidation status, HTS data, and importer-of-record details.
4. Identify entries that fall into more complex categories: AD/CVD, warehouse, drawback, reconciliation, or open protests.
5. Decide whether refunds should go directly to the importer or to a designated third party using CBP Form 4811.
6. Separate Phase 1 claims from entries that will require a later filing window or different strategy.

The companies that have done this work will file early and file correctly. The ones that wait for final instructions before getting organized will be starting from behind.

Where Does Mallory Alexander Fit In?

This is exactly where Mallory Alexander and our M-PACT team can help.

We support customers with:

• Entry population reviews to identify Phase 1 refund candidates versus complex entry holdbacks.
• HTS and Chapter 99 validation tied to IEEPA duties.
• ACE readiness and ACH refund setup coordination.
• CAPE declaration preparation and filing support.
• Strategy around complex entries involving AD/CVD, drawback, warehouse treatment, reconciliation, or unusual liquidation status.
• Importer-broker workflow alignment before claims are filed.

Refund recovery is not just about filing. It is about filing correctly, filing early, and protecting cash flow across the full entry population.

For companies that want a CAPE readiness review before the portal opens, Mallory Alexander and our M-PACT team can help identify what belongs in Phase 1, what needs cleanup first, and where your refund timeline could get delayed.