On March 31, U.S. Customs and Border Protection (CBP) filed an important status report in Atmus Filtration before the Court of International Trade. The update provides the clearest picture yet of what to expect from the first phase of the Consolidated Administration and Processing of Entries (CAPE).
Scope of CAPE Phase 1
CAPE Phase 1 will be limited in reach. It will apply only to entries that remain unliquidated or are still within the 90-day voluntary reliquidation window under 19 U.S.C. § 1501. Despite recent court orders extending relief to finally liquidated entries, those entries will not be included at this stage—though CBP says it plans to incorporate them in a future phase.
The system will accept entries with statuses such as “Suspended,” “Extended,” or “Under Review,” along with warehouse and withdrawal entries. However, refunds in these cases will be issued through the normal liquidation process rather than immediately. This includes entries subject to antidumping and countervailing duties (AD/CVD).
What’s Excluded
Several categories are explicitly excluded from Phase 1, including:
- Entries flagged for reconciliation
- Drawback-related entries
- Entries under an open protest
- Entries not filed in ACE or lacking a liquidation status
- Certain AD/CVD entries pending liquidation instructions
Processing Timeline
CBP states it may take up to 45 days from accepting a CAPE Declaration to review and liquidate entries, absent compliance concerns that require additional scrutiny.
What’s Coming Next
Future phases of CAPE are expected to expand functionality, including:
- Processing finally liquidated entries
- Enhanced compliance and validation tools
- Improved revenue enforcement mechanisms
- Support for non-ABI entries without entry summary lines
CBP makes clear it will actively review entries for compliance and may offset refunds where necessary. Ensuring documentation is complete and accurate remains critical.
*Disclaimer: The articles provided reflect our perspective and are created by our employees. They do not constitute legal documents or comprehensive information. For further inquiries, please contact our staff for additional details.