The IEEPA refund process continues to move forward, but U.S. Customs and Border Protection (CBP) has temporarily delayed the launch of CAPE Phase III while additional system programming is completed.

According to CBP’s latest update to the Court of International Trade (CIT), the delay affects Phase III only. CAPE Phases I and II remain fully operational, with eligible declarations continuing to be accepted and processed.

CAPE Phase III was originally expected to launch in August but has been temporarily delayed due to additional technical programming requirements. CBP is developing new system validations before processing certain finally liquidated entries covered by Court of International Trade litigation.

CAPE Phase III will address entries that liquidated past the 80-day clock that require re-liquidation for which are covered under a filed U.S.C 1581(i) suit by the importer of record with the Court of International Trade. Entries filed under a recon 09 entry type are not eligible for refund in CAPE III at this time.

A new implementation date has not yet been announced, and additional categories of entries are expected to be addressed in future CAPE development. CBP advises that entries flagged for reconciliation with a reconciliation entry already on file with CBP will be included in a future phase of CAPE development as will entries under protest, drawback, reconciliation, and entries in final liquidation status (80+ days).

At 721 Logistics, we continue to closely monitor CBP guidance, CAPE developments, and activity before the Court of International Trade to help our clients stay informed as the process evolves.

Current clients should refer to the detailed updates distributed directly by our Compliance team for additional information regarding CAPE eligibility and potential next steps. If you need a previous update resent, please contact info@721logistics.com or your 721 representative.