CBP filed a new declaration with the U.S. Court of International Trade on September 15, providing another update on IEEPA tariff refunds being processed through CAPE.

The biggest update is that CBP stated CAPE Phase 3 is scheduled to deploy on October 6, 2026. Phase 3 applies to finally liquidated entries filed by plaintiffs where the Court has ordered reliquidation. Plaintiffs who submitted a valid importer of record number to CBP by July 30, 2026, will be able to file CAPE declarations for Phase 3 as of October 6. CBP also stated that additional instructions will be provided to plaintiffs who submitted an importer of record number after July 30.

CBP also reported continued progress through CAPE. As of September 11, CBP reported that 286,044 CAPE declarations had been submitted, with 201,293 passing file validations. Those declarations cover 27.2 million entries, and 19.94 million accepted entries have been liquidated and/or reliquidated without IEEPA duties.

CBP further reported that approximately $134.7 billion in potential and certified refunds has been accepted for CAPE processing. Of that amount, approximately $122 billion, including duties plus interest, has been completed, certified by CBP, and sent to Treasury for disbursement.

A few important items for importers to note:

• As of September 11, 6.1 million entries included on CAPE declarations failed entry-level validations.
• As of September 11, 20,184 refunds, totaling approximately $1.3 billion, have not been transmitted to Treasury because ACH information has not been provided by the importer of record or its authorized CBP Form 4811 designee.
• Existing CAPE functionality for reconciliation-flagged entries remains available for certain unliquidated entries or entries liquidated within the prior 80 days where no Type 09 reconciliation entry has been filed.

RESOURCES

Review the September 15 CBP Declaration
Visit our IEEPA Tariff Refund Resource Center
Southern Star Navigation is actively monitoring IEEPA tariff refund developments, CAPE processing updates, Phase 3 activity, reconciliation-flagged entries, and CBP refund guidance as this process continues.

If your company has IEEPA refund eligibility, now is a good time to review your CAPE status, entry validation results, liquidation or reliquidation status, IOR information, and ACH or CBP Form 4811 information.

Contact our team at 833-782-7628 with questions or to review what may need attention.