U.S. Customs and Border Protection (CBP) has released important interim guidance addressing a key operational challenge for the trade community: how to handle reconciliation filings for import entries that contain IEEPA duties. These updates can be found in the FAQ section on CBP’s main IEEPA duty refunds page.
This update provides much-needed direction, given that entries flagged for reconciliation are excluded from IEEPA refunds via the CAPE system during the Phase I roll-out. CBP has stated that subsequent phases of CAPE will include the ability to request IEEPA refunds on reconciliation-flagged entries, but a timeline is not yet available for this development.
Sequencing strategy
CBP is signaling a clear sequencing strategy to reduce the risk of filing conflicts and help preserve refund eligibility under CAPE.
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- Delay When Possible: Delay filing reconciliation entries (Type 09) to allow CAPE declaration to be filed and processed first.
- Exception: Imminent Reconciliation Deadlines - If deadline is near (<30 Days) - Proceed with filing the reconciliation entry.
- If the reconciliation deadline is approaching (i.e., less than 30 days remaining):
- DO NOT: Include increase of IEEPA duties in the reconciliation filing
- DO: Deposit only duties, taxes, and fees owed excluding IEEPA increases
What if you’ve already filed reconciliation against an entry with IEEPA duties?
CBP is still developing guidance for entries where reconciliation has already been filed. Additional instructions will be issued through future CSMS messages.
Other things to remember about 2025 Consumption Entries included on Reconciliation Filings:
- Entries with separate bonds or sureties must be reconciled on separate filings
- All classification changes must be completed before filing reconciliation
- PSC and Protest changes should be finalized before reconciliation is filed
Next Steps
- Actively manage filings and deadlines to avoid conflicts and preserve refund opportunities
- Identify reconciliation deadlines within 30 days
- Prioritize CAPE-first filing strategy where feasible
- Validate classifications and bond structures before filing
- Processes remain in transition - Monitor upcoming CBP CSMS guidance
Tradewin Support
CBP’s interim approach requires a sequenced, proactive strategy. Tradewin can assist in reviewing your post-entry and CAPE strategy, as well as supporting both Value and Reconciliation filings. We’re here to help.
