The IEEPA refund process continues to evolve as U.S. Customs and Border Protection (CBP) provides additional details on the development of its CAPE refund system. In its latest update to the Court of International Trade, CBP confirmed that CAPE Phase I remains active, outlined plans for CAPE Phase II, and provided a preliminary timeline for future refund processing phases.
One of the most significant developments in this latest update is CBP’s announcement that CAPE Phase II is currently in development and is anticipated to launch on June 29, 2026. According to CBP, this phase is expected to address entries flagged for reconciliation that have either not yet liquidated or have liquidated but remain within the applicable post-liquidation time period for correction.
CBP also provided insight into a future CAPE Phase III, which is anticipated to launch on or around July 29, 2026. This phase is expected to focus on entries that have already reached final liquidation and may require reliquidation. Based on the information currently available, these entries would generally need to be covered by litigation filed by the importer in the Court of International Trade before refund processing can occur.
Currently, not every entry type will be included in these upcoming phases. CBP has indicated that entries under protest, drawback claims, and certain finally liquidated entries not covered by ongoing litigation will likely be addressed in a future phase of CAPE development.
Importers should also remember that CBP now issues refunds electronically. Please verify that your ACH Refund Authorization information has been properly established within the ACE Portal, as CBP no longer issues refund checks.
At 721 Logistics, we continue to closely monitor CAPE developments, court decisions, and CBP guidance. As new phases are implemented and additional instructions are released, our team will continue helping our clients understand how these changes may impact their entries and potential refund opportunities.
We encourage our clients to review the detailed compliance updates distributed by our Compliance team. If you need those communications resent, or have additional questions, please contact your 721 representative.