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U.S. Customs and Border Protection (CBP) has notified the Court of International Trade (CIT) that Phase 3 of its Consolidated Administration and Processing of Entries (CAPE) will deploy on October 6, 2026.

Phase 3 of CAPE, which is CBP’s automated systems for processing refunds of tariffs imposed under the International Emergency Economic Powers Act (IEEPA), covers finally liquidated entries filed by plaintiffs for which the CIT has specifically ordered reliquidation.

Brandon Lord, the Executive Director of the Trade Programs Directorate in CBP’s Office of Trade, made this statement in a declaration submitted to the CIT on September 15, 2026.

The declaration also states that plaintiffs who submitted a valid importer of record (IOR) number to CBP by July 30, 2026, will be able to file CAPE declarations for Phase 3 as of October 6, 2026. Further, CBP stated it will provide additional instructions regarding CAPE Phase 3 to the plaintiffs who provided this IOR after July 30, 2026.

The Husch Blackwell International Trade and Supply Chain team will continue to monitor and provide updates on this investigation as they become available. If you have company specific questions or concerns, please contact your Husch Blackwell attorney.

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Photo of Robert Stang Robert Stang

Bob focuses his practice on customs and international trade law. He brings 30 years of experience to a wide range of issues that affect inbound and outbound goods, including tariff classification, valuation, country of origin marking matters, free trade agreements, and special trade…

Bob focuses his practice on customs and international trade law. He brings 30 years of experience to a wide range of issues that affect inbound and outbound goods, including tariff classification, valuation, country of origin marking matters, free trade agreements, and special trade programs. He also has extensive customs compliance experience and regularly assists importers facing U.S. Customs and Border Protection (CBP) audits, penalties, seizures, redelivery notices and other agency enforcement activities. Bob works with importers and exporters proactively to achieve cost savings and structure programs that meet CBP “reasonable care” requirements. He also handles supply chain security issues, including Customs-Trade Partnership Against Terrorism (C-TPAT) enrollment, verification and annual reviews.

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Photo of Eric Dama Eric Dama

Eric works closely with in-house counsel and foreign trade teams to help exporters navigate an increasingly complex international trade landscape.

Eric guides U.S. and international companies through export licensing and classification requests, voluntary-self disclosures, international trade due diligence, and other regulatory matters. In…

Eric works closely with in-house counsel and foreign trade teams to help exporters navigate an increasingly complex international trade landscape.

Eric guides U.S. and international companies through export licensing and classification requests, voluntary-self disclosures, international trade due diligence, and other regulatory matters. In addition, Eric helps clients navigate internal and external investigations and enforcement actions, as well as internal compliance and training programs. He works with clients in a variety of sectors and industries, including aviation, manufacturing and equipment, cybersecurity, technology, defense contracting, logistics, energy, consumer products, and healthcare.

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