Why CAPE Refunds Arrive in Batches: The Liquidation-Date Rule
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TL;DR — CBP issues CAPE refunds by IOR plus liquidation date — not by CAPE Declaration date. An importer who filed 100 entries in one declaration may receive a refund for only the entries already liquidated, with the rest arriving in separate ACH payments as each liquidation cycle completes. Standard liquidation is 314 days from entry date. Unliquidated entries accepted in CAPE are set to liquidate 45 days from CAPE acceptance per CSMS #68340863.
How CBP groups refunds for payment
CSMS #68340863 (April 13, 2026) sets the rule directly: "The individual entry summary refunds will be consolidated by IOR or designated 4811 party and liquidation date before they are dispersed in one lump sum."
This means three things at the payment level:
First, one ACH transfer covers all entries from a single IOR that share the same liquidation date. Even if those entries were filed on different CAPE Declarations weeks apart, they batch into one payment if their liquidation dates align.
Second, a single CAPE Declaration with 100 entries spread across 20 different liquidation dates produces up to 20 separate ACH payments, not one.
Third, CBP confirms cross-declaration consolidation directly in the same CSMS: "These instances occur when entry summaries from different CAPE declarations are on one consolidated refund. Examples of such instances include entry summaries under review, suspended, or extended status prior to the CAPE declaration being accepted; the entry summary is a warehouse or warehouse withdrawal; or the entry summary is selected for review by CBP after the CAPE declaration is accepted."
Importers commonly expect "one Declaration = one payment" because the Declaration is what they submit. CBP's actual grouping is invisible at filing time and only becomes visible in REV-615 after entries are processed.
The two liquidation tracks under CAPE
Phase 1 covers two distinct sets of entries with different refund timelines. Both are defined in CSMS #68340863.
Track 1: Already liquidated within the 80-day window. Per CSMS #68340863: "Liquidated entry summaries will reliquidate the next business day." Refund follows typically within 60-90 days. Total wait from CAPE acceptance to ACH: roughly 60-90 days.
Track 2: Unliquidated at filing. Per CSMS #68340863: "unliquidated entry summaries will be set to liquidate 45 days from the CAPE Declaration acceptance date, except for entries in suspended, extended, or 'under review' liquidation status." The same CSMS clarifies the full timeline: "This 60-90 day timeframe includes 45 days for CBP review plus additional time to process the refund through Treasury." So unliquidated entries: 45 days to liquidation, then refund within roughly 15-45 more days. Total wait: roughly 60-90 days from acceptance, with the back end of that window most common.
A single CAPE Declaration can contain entries on both tracks. Importers see early payments on Track 1 entries while Track 2 entries wait for their scheduled liquidation.
Two categories of entries don't follow either track. Per CSMS #68340863: "Entry summaries with extended, suspended, or 'under review' liquidation statuses will maintain their liquidation status, and the refund will be issued upon liquidation." Warehouse and warehouse withdrawal entries similarly maintain their liquidation status and refund when CBP processes them in the normal course.
How to predict when each remaining batch will arrive
The prediction requires the Liquidation Date field, which is not included in a default ES-003 export. You must manually add it before running the report.
In the ACE Portal Report Builder, edit the ES-003 column set and add Liquidation Status and Liquidation Date. Save the modified report.
Once you have the Liquidation Date for each entry:
- Group entries by Liquidation Date.
- For each group, add 60-90 days to the liquidation date — that is the window in which the ACH for that group will arrive.
- For unliquidated entries, count 45 days from CAPE acceptance to estimate liquidation date, then add another 15-45 days for refund processing.
Worked example. An importer filed one CAPE Declaration on April 22, 2026 with 14 entries. ES-003 with Liquidation Date added shows:
- 3 entries liquidated March 15, 2026 — refund expected mid-May to mid-June 2026
- 5 entries liquidated April 10, 2026 — refund expected mid-June to mid-July 2026
- 6 entries unliquidated — liquidation scheduled around June 6, 2026 (45 days from acceptance), refund expected mid-June to mid-July 2026
The first ACH would cover only the 3 March entries. Three more payment windows follow over the next two to three months.
What to do while you wait
Schedule REV-615 for recurring email delivery. CSMS #68536553 explicitly recommends this and references the Quick Reference Card for setup. Recurring delivery removes the need to log into ACE manually each week.
Reconcile each ACH as it arrives. When a payment lands, identify which liquidation-date group it covers using REV-615 — the only ACE report that ties payment to specific entry numbers per CAPE claim. The detailed reconciliation steps are in REV-603 doesn't match bank deposit.
Do not file a duplicate CAPE Declaration for the same entries. CAPE Declarations cannot be amended. If an entry is missing from a payment because it hasn't liquidated yet, it refunds in a later batch — adding it to a new Declaration produces an error, not a faster refund.
When a batch is genuinely delayed
Most patterns of "missing" payment are normal timing. A few mean something is wrong.
ES-022 still blank past day 60 from acceptance for an unliquidated entry. Liquidation should have completed by day 45, with ES-022 populating shortly after. A blank ES-022 at day 60 means the reliquidation hasn't run. Email IEEPARefunds@cbp.dhs.gov with the CAPE claim number.
REV-603 shows "Sent to Treasury" but no ACH arrives within 14 days. Treasury has the claim but the wire failed or stalled. Check REV-613 — if the entry appears there, the ACH was rejected, most often due to incomplete ACH Refund Authorization. Fix the enrollment and email frn-achrefundsupport@cbp.dhs.gov. CBP holds the funds until enrollment is corrected.
Refund Secondary Status shows "Funds Diverted." This isn't a delay — it's an offset. See why a CAPE refund came short for the mechanics.
Entries that will never batch under Phase 1
CSMS #68340863 lists the entry-specific validations that exclude entries from Phase 1. Three categories never batch:
- Entries flagged for reconciliation (Entry Type 09). These wait for Phase 2.
- Entries subject to AD/CVD pending liquidation per 19 USC § 1504(d). CSMS #68340863 explains: "In order to timely apply the liquidation instructions imposed by the Department of Commerce (DOC), an AD/CVD entry with a liquidation status of pending or for which DOC has issued liquidation instructions will not be accepted on a CAPE Declaration." These wait for Phase 2.
- Entries with final liquidation status. These cannot be reopened through CAPE. Refund requires a Form 19 protest filed within 180 days of liquidation, or CIT litigation.
CBP has not announced a timeline for Phase 2. Phase 1 covers approximately 82% of IEEPA entries per Greenberg Traurig analysis (May 8, 2026), leaving roughly 18% for Phase 2 or alternative paths.
Frequently asked questions
I filed 100 entries in one CAPE Declaration. Why did I only get a refund for 3? Standard liquidation-date batching. CBP grouped refunds by liquidation date per CSMS #68340863, and only 3 of your entries share a liquidation date that has already triggered an ACH payment. The other 97 refund in later batches as their liquidation cycles complete.
When will the other 97 arrive? Each remaining liquidation-date group triggers its own ACH payment 60-90 days after liquidation completes. Run REV-615 to see the breakdown by entry and add 60-90 days to each liquidation date for a predicted window.
Can I see which entries are in each batch in advance? Yes. REV-615 lists entries per CAPE claim grouped by liquidation date. ES-022 with the Liquidation Date column added does the same.
Will unliquidated entries refund faster under CAPE than they would otherwise? Yes. Per CSMS #68340863, unliquidated entries accepted in CAPE are set to liquidate 45 days from the CAPE Declaration acceptance date. The standard liquidation cycle is 314 days from entry date. CAPE compresses unliquidated-entry refund timing to roughly 60-90 days total from acceptance.
My entries are all unliquidated. How long should I wait before contacting CBP?
Allow at least 45 days from CAPE acceptance for liquidation to run, then another 15-45 days for refund processing. If ES-022 is blank past day 60 from acceptance, email IEEPARefunds@cbp.dhs.gov with the CAPE claim number.
My entries are in "extended" or "suspended" liquidation status. When do they refund? Per CSMS #68340863, these entries maintain their existing liquidation status. The refund issues when the entry liquidates through CBP's normal course — there's no predictable timeline tied to CAPE acceptance.