Dear client,

U.S. Customs and Border Protection (CBP) will deploy Phase 3 of the Consolidated Administration and Process of Entries (CAPE) in ACE on October 6, 2026.

This new phase covers finally liquidated entries filed by plaintiffs for which the Court of International Trade (CIT) has ordered reliquidation regarding IEEPA duties.

Timeline and eligibility

According to CBP’s Executive Director of Trade Programs, the timeline for filing declarations depends on when your Importer of Record (IOR) number was submitted:

• Submitted by July 30, 2026: You can file CAPE declarations for Phase 3 starting October 6, 2026.
• Submitted after July 30, 2026: CBP will provide additional instructions regarding CAPE Phase 3 at a later date.

Missing ACH data halts $1.3B

While CBP has processed approximately 27.2 million entries through CAPE since April (accounting for $134.7 billion in potential and certified refunds), a significant issue is causing delays for many importers.

As of September 11, over 20,000 refunds valued at approximately $1.3 billion have not been transmitted to the Treasury Department. This delay is happening because the importer of record—or its authorized CBP Form 4811 designee—has not provided Automated Clearing House (ACH) account information.

We will continue to monitor CAPE activities and provide further updates as they become available.

In the meantime, if you want to ensure your ACH setup is correct to avoid payment delays, or if you need to talk through your specific CAPE eligibility, we're glad to help.

Reach out to our US Trade Compliance team directly for assistance in verifying your CBP Form 4811 and securing your eligible refunds.