Available now
Phases 1 and 2; limited plaintiff Phase 3
Phase 3 is live for finally liquidated entries covered by a CIT reliquidation order. The first group supplied a valid IOR number to CBP by July 30.
See which IEEPA entries can move through CAPE now, how to avoid ACE validation delays, and when a protest or CIT review may be needed.
Current CAPE status · Reviewed October 22, 2026
Move eligible entries now, verify ACH before filing, and get case-specific guidance where CAPE does not yet provide a clear path.
Available now
Phase 3 is live for finally liquidated entries covered by a CIT reliquidation order. The first group supplied a valid IOR number to CBP by July 30.
Prepare before filing
CBP’s September 30 FAQ explains Form 5106 updates through ACE Portal or a broker using ABI Action Code U. Verify importer identity and ACH banking before filing.
Needs case review
Class certification does not itself order refunds or create a general CAPE filing procedure. Later IOR submitters, non-plaintiffs, postal claims, and surety-paid duties need case-specific review.
CAPE simplifies the intake process, but CBP still validates the entries, recalculates duties, and controls when refunds are released.
Confirm the entry has IEEPA Chapter 99 duties and is either still unliquidated or not more than about 80 days past liquidation. Use our interactive checker to verify.
Set up ACE access, enroll ACH refunds, and prepare an entry-number-only CSV that matches your importer or filing account.
Upload up to 9,999 entry numbers, clear ACE validations, and monitor consolidated refunds through the new CAPE reporting workflow.
Timely analysis of CAPE filing windows, Phase 3, CIT orders, and the practical steps importers can take now.
Judge Eaton ordered CBP to reliquidate finally liquidated entries for 3,700+ IEEPA plaintiffs. Learn what the order requires and how to submit your CAPE declaration.
Read articleOn October 8, the CIT certified an IEEPA importer class. Review who is included, what certification does not grant, and the next court dates.
Read articleFinally liquidated IEEPA entries remain outside a general CAPE Phase 3 lane. Compare protective protests, CIT review, and the latest CBP refund posture.
Read articleTrack the October 6 limited CAPE Phase 3 launch, CIT’s IEEPA class ruling, CBP refund data, and importer protest deadlines.
Read articleWe separate confirmed CBP instructions and court filings from developing reports, then translate them into practical next steps.
$132.5B
The latest quantified CBP declaration covers activity through August 21, 2026.
August 25 Lord DeclarationAuthorized filers
A CAPE declaration is limited to the importer of record or the broker that filed the entry summary.
CBP CSMS #6834086322,170
As of October 2, 20,362 refunds totaling about $1.1 billion were held for missing ACH information.
August 25 Lord DeclarationTell us about your imports — we'll review your options and reach out within 24 hours.
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