Overview
Importers seeking IEEPA tariff refunds should prepare now for the next phase of the refund process. 
On September 15, 2026, U.S. Custom and Border Protection (CBP) notified the Court of International Trade that (CIT) that the Consolidated Administration and Processing of Entries (“CAPE”) Phase 3 will deploy on October 6, 2026. This marks an important milestone in the implementation of the CAPE process for importers seeking relief.
When Can Importers File Declarations?
According to the CBP, importers who submitted a valid importer of record (“IOR”) number to CBP by July 30, 2026, will be eligible to file CAPE declarations for Phase 3 beginning October 3, 2026. Further, CBP stated it will provide additional instructions to importers that submitted valid IOR information after the July 30 deadline.
What Importers Should Do Now
Importers seeking refunds should consider taking the following steps:
- Confirm whether a valid IOR number was submitted to CBP and when it was provided.
- Monitor CBP communications for additional Phase 3 filing instructions and deadlines.
As we previously reported in IEEPA Tariff Refunds Authorized: What Importers Need to Know, given the uncertainty surrounding refunds for finally liquidated entries, affected importers should consult with experienced international trade counsel to assess their potential recovery and determine whether litigation should be considered.
