What CBP Reconciliation Means for Your IEEPA Refund
If your entries are flagged for reconciliation, you’re in a better spot than most importers chasing IEEPA refunds. Those entries haven’t finally liquidated yet. Right now, that’s the whole game.
Here’s why.
What reconciliation actually is
Reconciliation is CBP’s pressure valve for a basic fact of trade: you don’t always know everything at the time of entry. The final value of an assist, royalty payments, a free trade agreement claim, an HTS 9802 value, sometimes those numbers aren’t settled when the goods hit the port.
So instead of guessing wrong and fixing it later, you file the entry summary with your best available information and flag the entry. The flag is a notice of intent that tells CBP a Reconciliation is coming. When the real numbers come in, you file the Reconciliation, and CBP liquidates it with a single bill or a single refund.
The clock: you file within 12 months of the earliest entry for certain free trade agreements, or within 21 months for everything else. One Reconciliation can cover up to 9,999 underlying entries. You can read CBP’s own breakdown here.
A Reconciliation is treated like any other CBP entry for liquidation and protest. Same rights, same clocks, once it liquidates.
Why this matters for your refund
A flagged reconciliation entry stays open until you file the Reconciliation. Open means not finally liquidated. And not finally liquidated is the line that decides who gets refunded the easy way.
CBP’s CAPE Phase 2 rollout is built for exactly these entries. The importers fighting it out in court are the ones whose entries already went final. The importers with open reconciliation flags are the ones CBP can still refund administratively, without a court order, without a lawsuit.
If you’ve been flagging entries for reconciliation as a matter of routine, that routine just became an asset. If you’re not sure where your entries stand, that’s worth finding out before the windows close.
Not sure where your entries sit?
We can pull your entry data and tell you which entries are open, which are flagged for reconciliation, and which are at risk of going final before you can act. No guessing.
Reach out and we’ll take a look.
Frequently Asked Questions
Q: Can I get an IEEPA refund on a reconciliation entry without filing a lawsuit? Yes. Because a flagged reconciliation entry hasn’t finally liquidated, CBP can refund it administratively through its CAPE process—no court order and no individual lawsuit required. The importers who have to file suit are the ones whose entries already went final. Reconciliation entries that are still open avoid that fight.
Q: What is CAPE Phase 2 and which entries does it cover? CAPE Phase 2 is the stage of CBP’s refund rollout aimed at entries in reconciliation status. Phase 1 covered unliquidated entries and entries within 80 days of liquidation. Phase 2 extends the administrative refund path to reconciliation-flagged entries, which remain open until the importer files the Reconciliation. It’s the mechanism that lets these importers recover IEEPA duties directly.
Q: Which IEEPA duties are refundable on these entries? The refundable duties are the IEEPA tariffs the Supreme Court invalidated in February 2026, including the reciprocal tariffs and the fentanyl-related tariffs, paid on entries dating back to early 2025. If you paid IEEPA duties on a reconciliation-flagged entry, those amounts are eligible to be refunded with interest once the entry is processed through CAPE.
Q: Could I lose my IEEPA refund if my reconciliation entry finally liquidates? The risk exists if an entry slips into final liquidation before it’s handled, because finally liquidated entries are the contested group that may require a court order to refund. The practical takeaway is to know where each entry sits in its timeline. An open reconciliation entry is in the favorable bucket today, but that status doesn’t last forever, so the entries are worth monitoring.
Q: How do I claim an IEEPA refund on reconciliation entries? Refunds are claimed by submitting a CAPE declaration through CBP’s ACE Secure Data Portal—a file listing the eligible entries. CBP validates the entries and, once accepted, issues the refund electronically, generally within 60 to 90 days absent compliance issues. The first step is confirming which of your reconciliation entries carry refundable IEEPA duties.
