CBP’s decision to open CAPE to certain reconciliation-flagged entries on June 29 gives importers a narrow chance to recover IEEPA duties on entries that had been excluded from Phase 1, but only if no reconciliation entry has yet been filed and the entry still falls within CAPE’s 80-day liquidation window. The update turns filing order into the decisive compliance issue: once a reconciliation entry is on file, the underlying entry is out of CAPE for this phase, making immediate review of pending recon-flagged entries essential for importers trying to preserve refund eligibility.
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