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CAPE Phase 2 opened new refund eligibility on June 29, 2026. See what changed and why now is the time to refer clients through MyGig.
Some of your clients are sitting on a refund they do not even know is actionable yet. Others could lose that chance before you ever get to make the referral.
The United States Customs and Border Protection (CBP) opened Consolidated Administration and Processing of Entries (CAPE) Phase 2 on June 29, 2026, the next stage of its International Emergency Economic Powers Act (IEEPA) refund system. It adds a new category of entries into scope: Those flagged for reconciliation, which means clients who were shut out of Phase 1 may now qualify.
But qualifying is not the same as getting paid. Filing in the wrong order or too late can lock a client out of this phase permanently, and they may never know the window was open at all.
Here is what changed: The one filing mistake that can quietly disqualify a client and how referring them now through the IEEPA Concierge Referral Program puts them ahead of it.
CBP's CAPE system now processes a second category of entries: Those flagged for reconciliation. Phase 1 launched in April 2026 and covered unliquidated and recently liquidated entries.
At a June 9, 2026, hearing before the Court of International Trade, CBP's executive assistant commissioner for trade, Susan Thomas, estimated this new phase covers roughly $28.7 billion in refunds across about 2.8 million entries, a pool that likely includes clients you already work with. For the fuller CBP/CAPE update history, including portal issues and filing guidance worth sharing with clients, see the AAS IEEPA Resource Hub.
For your clients, this means a wider slice of their IEEPA tariff refund may now be actionable, but only if the entries are prepared and filed correctly. That is the gap the IEEPA Concierge Referral Program is built to close.
Entries eligible under this phase are flagged for reconciliation, specifically entry types 01, 02 and 06, where the Type 09 reconciliation entry has not yet been filed. Eligible entries must also be unliquidated or within 80 days of liquidation, the same window used in Phase 1.
If a client's reconciliation entry has already been filed with CBP, it will not qualify under this round. Note that the refund right generally runs through the client's status as Importer of Record, so any filing still requires their authorization, even after you refer them to the IEEPA Concierge Referral Program.
But being flagged for reconciliation is not enough on its own. Older entries can miss the window entirely without a client ever realizing it.
Some clients may already be out of the running. Reconciliation entries filed before roughly May 31, 2025, likely liquidated on a standard 314-day cycle, which puts them more than 80 days outside this window. If a client falls into that group, this phase will not capture them, and they may need an entirely different path.
This is not a simple file-and-get-paid process, and the numbers back that up. Since Phase 1 launched, importers have run into:
A client who moves too slowly, or coordinates the filing order incorrectly with their broker, can lose the opportunity without ever knowing it was on the table. That is exactly the kind of operational risk your clients should not be managing alone, and exactly why a referral into a managed program is worth more today than it was during Phase 1.
Every phase adds new filing rules and new ways for a claim to go wrong. Clients who wait to see how Phase 2 shakes out risk missing filing windows, especially for older reconciliation entries and clients who try to self-file risk the same portal errors, rejections and lockouts that are already affecting thousands of importers.
Referring a client into the IEEPA Concierge Referral Program now, while this phase is fresh, puts them ahead of both problems. When you make the referral, AAS steps in as the back-end filing partner and handles the rest: Confirming which entries are eligible now, validating entry-level data, preparing CAPE-ready filings, coordinating Type 09 timing with the client's broker and monitoring the claim through submission, review and payout. You keep the client relationship. AAS handles the filing and processing work behind it.
If you have a client who paid IEEPA duties in 2025 or 2026, whether or not they have filed anything yet, learn more about the IEEPA Program; it is one login away through your MyGig affiliate program account. Log in, view the IEEPA Offering Page in MyGig, submit the referral and AAS takes it from there.
