The IEEPA refund process continues to move forward as U.S. Customs and Border Protection (CBP) expands its Consolidated Administration and Processing of Entries (CAPE) system. In its latest update to the Court of International Trade, CBP confirmed that CAPE Phase II officially launched on June 29, 2026, allowing additional eligible entries to begin the refund process.

CAPE Phase II applies to entries flagged for reconciliation that have not yet liquidated or have liquidated but remain within the applicable post-liquidation timeframe. This expansion allows more importers to submit eligible entries for potential IEEPA duty refunds.

CBP also confirmed that refunds are now being issued by the U.S. Treasury, with many payments expected within 60 to 90 days after a CAPE declaration is accepted. However, filing errors continue to delay processing. The most common issues include importer-of-record and filer mismatches, incorrect entry numbers, improperly formatted submission files, and missing ACH Refund Authorization information in the ACE Portal.

Looking ahead, CAPE Phase III remains in development and is currently anticipated to launch around July 29, 2026. Based on current guidance, this phase is expected to address certain finally liquidated entries that are covered by active litigation and will address entries that 1) liquidated past the 80-day clock that require re-liquidation for which are 2) covered under a filed U.S.C 1581(i) suit by the importer of record with the Court of International Trade. 

Entries under protest, drawback, reconciliation (09 entry), and final liquidation not covered under the CIT litigation will be addressed under a future CAPE Phase.  The eligibility and official outcome are unknown currently. Although progress continues, the legal process surrounding IEEPA refunds is still ongoing. As a result, eligibility for some entries, particularly those that are finally liquidated, remains subject to future court decisions and additional CBP guidance.

Importers should also be aware of additional tariff developments on the horizon. The current 10% Section 122 tariffs are scheduled to expire on July 24, 2026. In addition, proposed Section 301 sanction tariffs ranging from 10% to 25%, depending on the country of origin, are anticipated to take effect in late July or early August. As always, these timelines remain subject to change as additional guidance is released.

At 721 Logistics, we continue to monitor CAPE developments, court activity, and CBP guidance to help our clients stay informed and prepared. We also encourage current clients to review the detailed compliance updates previously distributed by our Compliance team. If you need those communications resent, please contact your 721 representative.