The below was taken in part from the NCBFAA:

US Customs and Border Protection (CBP) updated their IEEPA FAQ page on May 26th, 2026 with two (2) new responses, both addressing reconciliation.

We’d like to note in particular the advice to hold off on filing reconciliation unless your filing deadline is within 30 days. This appears to suggest the potential for a path to avoid paying additional IEEPA duties only to have them refunded: “if close to filing deadline … file the reconciliation entry and deposit the duties, taxes, and fees owed, without the increased IEEPA duties.”

(1) How does CBP currently address IEEPA refunds if CAPE declarations are not allowed to be filed for entry summaries flagged for reconciliation?

CBP is currently working on a phased solution to process unliquidated or liquidated (not more than 80 days beyond the liquidation date) entries flagged for reconciliation (Entry Types 01, 02, and 06) that are included on a CAPE declaration, and for which an Entry Type 09 has not yet been filed at the time of CAPE acceptance. The CAPE process does not prevent an entry from being reconciled; however, CBP suggests that the trade community hold reconciliation filings (Entry Type 09) unless the reconciliation filing deadline is close to expiring (less than 30 days) so that the CAPE declaration can be filed and processed first. CBP is also working on a solution for situations where the reconciliation entry is already on file. As these phases are deployed, CBP will issue Cargo Systems Messaging Service (CSMS) messages providing filing requirements and guidance.

(2) What should the trade do if they have a reconciliation filing deadline that is close to expiring for which the reconciliation will result in an increase in IEEPA duties?

Trade should file the reconciliation entry and deposit the duties, taxes, and fees owed, without the increased IEEPA duties.

NCBFAA members should direct CBP questions to:

• For technical questions about IEEPA refunds, email: IEEPARefunds@cbp.dhs.gov
• For general inquiries about IEEPA refunds, email: traderelations@cbp.dhs.gov

If you have any further questions or need additional support, please reach out to your RIM Representative.