You Were Excluded From Phase 1. Phase 2 Is Coming — Prepare Now.
CAPE Phase 1 covers most unliquidated entries and entries liquidated within 80 days. A significant portion of IEEPA tariff refunds are held in entries that did not qualify for Phase 1 — including entries under AD/CVD suspension, reconciliation entries, drawback entries, and entries with final liquidation beyond the 80-day window. CBP has not announced a Phase 2 timeline. Prepare your entry data now so you can file the moment Phase 2 opens.
Phase 2 Has No Timeline. Your Preparation Does.
CBP launched Phase 1 on April 20, 2026. Phase 2 — covering entries excluded from Phase 1 — has no announced launch date. Importers with excluded entries are waiting with no timeline and no official guidance beyond CBP's statement that these entries "are being evaluated for future phases."
The most complex excluded category is entries subject to Antidumping and Countervailing Duty suspension. Per the CBP Antidumping and Countervailing Duty Handbook, when Commerce issues an affirmative preliminary determination it orders suspension of liquidation of all affected entries. These entries are controlled by the Department of Commerce — not CBP — which is why they cannot run through CAPE Phase 1 simultaneously. When Commerce issues its final determination, CBP reliquidates the entries. Only then can the IEEPA component be separated and refunded.
Importers with AD/CVD entries need to document now: which entries carry AD/CVD codes alongside IEEPA HTS codes, what the current DOC determination status is, and whether suspension of liquidation has been lifted. That documentation is the foundation of a fast Phase 2 filing.
What entries are excluded from Phase 1 and will be in Phase 2?
Why are AD/CVD entries excluded from Phase 1?
Does interest still accrue on Phase 2 entries?
What should I do right now if my entries are excluded from Phase 1?
What is the reliquidation process when Phase 2 opens?
What Reliquidation Means for Your Entries
Phase 2 has no announced timeline — but the reliquidation process, the exclusion categories, and your preparation steps are all known now.
What Reliquidation Means
Reliquidation is CBP's process of reopening and adjusting a previously finalized entry. When a CAPE Declaration is accepted, CBP removes IEEPA HTS Chapter 99 codes from your entry summaries and reliquidates those entries at the corrected duty amount. For unliquidated entries, CBP sets a liquidation date 45 days from CAPE Declaration acceptance. For already-liquidated entries, reliquidation occurs the next business day after processing. Refunds are then consolidated and disbursed via ACH.
Why Your Entries May Be Excluded From Phase 1
Phase 1 explicitly excludes several entry categories: entries flagged for reconciliation and Entry Type 09; entries on drawback claims; entries covered by open protests; entries subject to Antidumping or Countervailing Duty orders for which the Department of Commerce has issued liquidation instructions pending under 19 U.S.C. § 1504(d); entries not filed in ACE; and entries for which liquidation is final and more than 80 days old. These categories represent a substantial portion of total IEEPA tariff exposure and will be addressed in future CAPE phases.
How to Prepare for Phase 2 Now
CBP has not announced a Phase 2 timeline. But preparation now means you can file immediately when Phase 2 opens — rather than spending weeks gathering data after the announcement. Identify all entries excluded from Phase 1. Document your AD/CVD case numbers, suspension dates, and Department of Commerce liquidation instruction status. Isolate IEEPA duty components from Section 232, Section 301, and other duty layers on the same entries. Have your ACE account and ACH banking already registered.
Everything You Need — For Free
Use our free tools to understand your excluded entry status, estimate your interest, and get answers about Phase 2 preparation.
Five Things Every Importer Must Know
The five technical pillars of IEEPA refund eligibility — Phase 1 and Phase 2. Liquidation status, ACH enrollment, entry formatting, interest calculation, and the exclusion categories that determine which phase your entries belong to.
Read the Quick Guide
2. ACH Enrollment — You must have a U.S. bank account registered in the ACE Secure Data Portal. This account must be separate from any ACH account used to pay duties to CBP.
3. Entry Formatting — All entry numbers must be exact 11 alphanumeric characters. One bad character rejects the line.
4. Interest Calculation — Statutory interest accrues from the original entry payment date at 7% annually (non-corp) or 6% (corp), compounded quarterly per 19 U.S.C. 1505 — for Phase 1 and Phase 2 entries alike.
5. Phase 1 Exclusions — Reconciliation entries, drawback entries, AD/CVD entries under § 1504(d), open protest entries, and entries not filed in ACE are excluded from Phase 1 and will be addressed in Phase 2.
Read the Full Filing Guide →
CAPE Pre-Filing Eligibility Screener
Answer 6 questions and get an instant technical readiness assessment. Know whether your entries qualify for Phase 1 or will need to wait for Phase 2 — and what to do to prepare in either case.
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TariffGuru's free AI Recovery Agent is trained on CBP CAPE documentation, the CBP Antidumping and Countervailing Duty Handbook, Federal Register interest rates, and CIT court orders. No account required.
Get Free Phase 2 Guidance at TariffGuru.com →Federal Statutory Interest Calculator
Interest accrues on Phase 2 entries just as it does on Phase 1. Calculated per 19 U.S.C. 1505 and 26 U.S.C. 6621. The longer your entries wait for Phase 2, the more interest accumulates on your behalf.
Use the Full Calculator Below →Federal Statutory Interest Calculator — IEEPA Tariff Refund Overpayment Rates
Statutory interest on IEEPA tariff refunds accrues from the date the original duties were paid through the date CBP issues your refund. This is not optional — it is a legal entitlement under federal statute.
The applicable rates, confirmed across multiple Federal Register publications, are 7% annually for non-corporate importers and 6% annually for corporate importers, compounded quarterly.
For entries paid in April 2025, this means more than a full year of interest accrues on top of your principal refund amount before CBP issues payment — whether those entries are in Phase 1 or Phase 2.
Source: 19 U.S.C. 1505 · 26 U.S.C. 6621 · Federal Register Vol. 90 No. 186 (September 29, 2025) · Federal Register Document 2026-01175 (January 22, 2026) · Revenue Ruling 2025-22
Estimate based on statutory rates per 19 U.S.C. 1505 and 26 U.S.C. 6621, compounded quarterly. Actual amounts depend on entry-level CBP data and the refund process established by the Court of International Trade.
File It Right the First Time
From the $97 self-filing toolkit to full institutional data formatting and AD/CVD suspension review — TariffGuru.com provides the technical infrastructure for Phase 1 and Phase 2.
Federal Recovery Toolkit
- Master CAPE CSV template (CBP-compliant, pre-formatted)
- ACE portal data extraction guide
- CBP error dictionary — every rejection code explained
- HTS reference library for IEEPA-subject goods
- USITC duty handbook and HTS classification guide
- Supreme Court ruling analysis (Learning Resources v. Trump)
- Federal Register interest rate documentation
- 12-point pre-submission filing readiness checklist
- Phase 1 exclusion reference guide
Institutional Data Services
- Professional CAPE CSV data formatting at $1 per line
- $1,500 minimum — covers up to 1,500 entry lines
- $4,500 Institutional Data Audit — pre-submission error scan
- PDF Risk Report identifying rejection risks before filing
- Section 301 / IEEPA duty stacking analysis
- AD/CVD suspension review and Phase 2 preparation
- Full concierge with licensed customs practitioners available
Ask Any Question About Phase 2 and Reliquidation — Free
TariffGuru's free AI Recovery Agent is trained on CBP CAPE documentation, the CBP Antidumping and Countervailing Duty Handbook, Federal Register interest rates, and CIT court orders. Ask anything about your excluded entries, reliquidation timing, or Phase 2 preparation. No account required.
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Stay Ahead of the Process
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