Jane Dempsey

Key Takeaways U.S. Customs and Border Protection (CBP) will launch Phase 1 of CAPE on April 20, giving many importers their first access to the ACE-based path to request IEEPA duty refunds. More complicated entries – including those involving certain AD/CVD orders, protests, drawback, reconciliation and liquidated entries that are more than 80 days past liquidation – remain outside Phase 1 or will follow a different timeline.

Key Takeaways U.S. Customs and Border Protection (CBP) will launch the first phase of its Consolidated Administration and Processing of Entries (CAPE) tool to process International Emergency Economic Powers Act (IEEPA) duty refunds on April 20. Phase one is limited to most unliquidated entries and entries within 80 days of liquidation, while more complex scenarios will be addressed in later phases as more functionality is added to the CAPE system.

Key Takeaways Covered patented pharmaceuticals, APIs and key starting materials face a default 100% ad valorem duty, subject to express carveouts and alternative tariff pathways. The tariffs will take effect on July 31, 2026 for companies listed in Annex III, and on Sept. 29, 2026 for other companies. Companies with U.S. Department of Commerce-approved onshoring plans may qualify for a 20% rate, which rises to 100% on April 2, 2030.