CBP Reports Major Progress on IEEPA Refunds; CAPE Phase 3 Launches October 6

  • Effective Date: September 17, 2026
  • Affected Regions: North America
  • Advisory Type: Tariff

U.S. Customs and Border Protection (CBP) has made a declaration to the U.S. Court of International Trade on the status of IEEPA duty refunds being processed through its Consolidated Administration and Processing of Entries (CAPE) system.

CAPE Phase 3

CBP confirmed that CAPE Phase 3 will be deployed on October 6, 2026. This phase will allow eligible plaintiffs to seek refunds on finally liquidated entries covered by court-ordered reliquidation. Importers that provided a valid importer of record number to CBP by July 30, 2026, will be able to begin filing Phase 3 declarations on that date.

Key highlights

  • More than 286,000 CAPE declarations have been submitted, with over 201,000 accepted for processing, covering approximately 27.2 million entries.
  • CBP reports that approximately $134.7 billion in potential and certified refunds have been accepted into CAPE. Of that amount, approximately $122 billion (including interest) has been certified and transmitted to the U.S. Treasury for payment.
  • Approximately 20,184 refunds totaling $1.3 billion remain on hold because the importer of record has not provided ACH banking information.
  • Since June 29, 2026, CAPE has supported certain reconciliation-flagged entries that are unliquidated or recently liquidated and do not yet have a filed reconciliation entry.

CBP is expected to provide further guidance on the filing of CAPE Phase 3.

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