US Customs Launches Phase 3 of IEEPA Tariff Refund Process Today

CBP's CAPE system phase 3 goes live Oct. 6, allowing importers to claim IEEPA tariff refunds on entries liquidated more than 80 days ago — limited to importer plaintiffs with pending cases at the Court of International Trade.
Why it matters
This is the next step in returning hundreds of billions of dollars in tariffs after federal courts struck down the IEEPA duties. Citing CBP data, law firms report 27.1 million entries worth $134.7 billion processed as of Sept. 11, with $122 billion certified to the Treasury. Eligible importers can now begin substantive refund claims.
Full report
Multiple US law firms, citing a CBP declaration filed with the Court of International Trade (CIT) on Sept. 15, report that phase 3 of the CAPE system — the platform managing IEEPA tariff refunds — went live today, Oct. 6, 2026. Phase 3 lets importers seek IEEPA tariff refunds on entries liquidated more than 80 days ago; phase 1 had covered only unliquidated entries and those liquidated within 80 days.
Eligibility is narrow: only importer plaintiffs with pending refund suits at the CIT, who submitted their importer number to CBP by July 30, may file.
The legal basis is the Supreme Court's ruling in Learning Resources v. Trump that IEEPA did not authorize the president to impose the tariffs. Citing CBP data through Sept. 11, tariffstool reports 27.1 million entries processed ($134.7 billion), with $122 billion certified to the Treasury.
(Based on law-firm analyses of CBP's official declaration; consult CBP's official guidance for filing details.)
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