CBP Updates IEEPA FAQ: Crucial Guidance on Reconciliation and CAPE Declarations

U.S. Customs and Border Protection (CBP) has issued an essential update to its International Emergency Economic Powers Act (IEEPA) FAQ page, delivering critical guidance on reconciliation entries and CAPE declarations. If your business handles entry summaries flagged for reconciliation, these changes will impact your filing timeline and cash flow strategy.

On May 26, 2026, CBP released two new responses addressing the intersection of CAPE declarations and the reconciliation process.

The most notable takeaway? CBP is explicitly advising the trade community to hold off on filing reconciliation entries unless your formal filing deadline is within the next 30 days. This temporary delay introduces a strategic pathway for importers to avoid paying additional IEEPA duties upfront, only to have them refunded later.

1. How CBP is Handling IEEPA Refunds with CAPE Declarations

A major pain point for trade professionals has been navigating IEEPA refunds when CAPE declarations cannot be filed for entry summaries flagged for reconciliation.

CBP clarified that they are actively working on a phased solution to process both unliquidated and liquidated entries (provided they are not more than 80 days beyond their liquidation date) that are flagged for reconciliation—specifically Entry Types 01, 02, and 06. This applies to entries included on a CAPE declaration where an Entry Type 09 (Reconciliation Entry) has not yet been filed at the time the CAPE is accepted.

Operational Tip: The CAPE process does not prevent an entry from being reconciled. However, CBP strongly suggests holding your Entry Type 09 filings until you are within 30 days of the expiration deadline. This allows the CAPE declaration to be filed and processed first.

For businesses that have already filed their reconciliation entries, CBP noted that a technical solution is also currently in development for those scenarios. Compliance teams should keep an eye out for upcoming Cargo Systems Messaging Service (CSMS) messages, which will provide detailed filing requirements as these phases roll out.

2. Approaching an Expiring Deadline? Leave Off the Increased IEEPA Duties

The second major update addresses an immediate compliance question: What should you do if you have a reconciliation filing deadline fast approaching, and the reconciliation will result in an increase in IEEPA duties?

CBP’s directive provides significant administrative and financial relief:

• The Mandate: Trade members should go ahead and file the reconciliation entry and deposit the standard duties, taxes, and fees owed—without including the increased IEEPA duties.

This is a massive win for importer cash flow, ensuring companies aren't forced to tie up capital in elevated duties while waiting for the technical infrastructure of the refund process to clear.

What This Means for Importers

This update indicates that CBP is prioritizing administrative flexibility to avoid unnecessary financial friction for businesses. By allowing the trade to pause Type 09 filings or omit increased IEEPA duties on expiring entries, they are creating a more pragmatic environment for compliance managers.

As your trusted logistics partner, ACM Logistics & Consulting is monitoring these updates in real-time. Reach out today to review your upcoming reconciliation timelines and ensure your filing strategy aligns with this new guidance.

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