CBP’s next CAPE phase will address court-ordered reliquidation of certain finally liquidated entries, while refund processing continues across millions of IEEPA-affected entries.
Phase 3 Expands CAPE Refund Processing
US Customs and Border Protection (CBP) will deploy Phase 3 of the Consolidated Administration and Processing of Entries (CAPE) functionality in the Automated Commercial Environment (ACE) on October 6, 2026.
The next phase will address finally liquidated entries filed by plaintiffs for which the US Court of International Trade (CIT) has ordered reliquidation.
According to a declaration filed by CBP Executive Director of Trade Programs Brandon Lord on September 15, eligible plaintiffs who submitted a valid Importer of Record (IOR) number to CBP by July 30, 2026, will be able to file CAPE declarations beginning October 6. CBP will provide additional instructions to plaintiffs who submitted their IOR numbers after the July 30 deadline.
Refund Processing Continues
CBP reported that, as of 3 p.m. ET on September 11, approximately 27.2 million entries with IEEPA duties had been processed through CAPE, representing approximately $134.7 billion in potential and certified refunds.
However, refund processing remains dependent on accurate payment information. During the same reporting period, 20,184 refunds valued at approximately $1.3 billion had not been transmitted to the US Department of the Treasury because the importer of record or its authorized CBP Form 4811 designee had not provided ACH account information.
CBP requires refund recipients to maintain valid banking information in the ACE Portal for electronic payment processing. Importers should review their refund account information to help prevent delays.
What Importers Should Know
As CAPE functionality expands, importers and customs brokers should continue monitoring CBP guidance and reviewing the status of affected entries.
Key considerations include:
- Phase 3 eligibility: Plaintiffs who submitted valid IOR numbers by July 30, 2026, may begin filing Phase 3 CAPE declarations on October 6.
- Refund account information: ACH information must be available to facilitate electronic refund transmission.
- Entry monitoring: Importers should track affected entries and monitor CBP communications for additional filing instructions.
CAPE is being implemented in phases to support the processing of IEEPA duty refunds across different entry scenarios. CBP will issue additional guidance as functionality becomes available.
Mohawk Global Trade Advisors can help importers navigate evolving customs requirements and refund-related considerations. Please contact your Mohawk Global representative with questions about how these developments may affect your business.