The IEEPA refund process is entering its next stage, with CAPE Phase III scheduled for deployment on October 6, 2026.

Following previous delays as U.S. Customs and Border Protection (CBP) worked through additional system requirements, Phase III is expected to expand CAPE processing to certain finally liquidated entries associated with importers who have filed IEEPA refund litigation with the U.S. Court of International Trade (CIT).

Who Will CAPE Phase III Apply To?

Unlike earlier CAPE phases, Phase III has specific eligibility requirements tied to an importer’s entry status and litigation. Generally, eligible entries must have reached final liquidation and be associated with an importer covered by a qualifying CIT case and court-ordered reliquidation.

Additional steps between an importer’s trade attorney, the CIT, and CBP may also be required before entries can be processed through Phase III.

Importantly, not every finally liquidated entry will be eligible for the October 6 deployment. Other entry types and circumstances are expected to be addressed through future CAPE development as the refund process continues to evolve.

IEEPA Refunds Continue to Develop

CAPE was developed within CBP’s Automated Commercial Environment (ACE) to facilitate the processing of eligible IEEPA tariff refunds. As additional phases have been introduced, the system has expanded to address different entry statuses and circumstances.

Phase III represents another important step in that process, but eligibility can vary significantly by importer and entry.

At 721 Logistics / J&K Fresh East, we continue to closely monitor CAPE, CBP guidance, and Court of International Trade developments so our clients can stay informed as new phases are implemented.

Current clients have received additional guidance from our Compliance team regarding CAPE Phase III eligibility and preparation. If you have questions about your entries or need a previous compliance update resent, please contact your 721 representative.