On October 6th, 2026, CBP plans to open CAPE Phase 3 for finally liquidated entries covered by court-ordered reliquidation. Eligibility is presently narrower than some headlines suggest: the importer generally must be a plaintiff in pending IEEPA litigation, the entries must fall under a reliquidation order, and the importer must have submitted its IOR number to CBP by July 30. Later submissions require additional instructions.
Why does this matter?
This provides a refund path for entries otherwise beyond ordinary protest or reliquidation periods, but it is not presently a blanket refund procedure for every importer.
What can you do?
Reach out to your broker and request the separation of finally liquidated entries from unliquidated or recently liquidated entries. Ask the broker to verify the status, court-order coverage, IOR submission date, ACH information, and Form 4811 refund designation.
Find out moreIEEPA Duty Refunds — U.S. Customs and Border Protection
