When will CAPE Phase 3 launch?

CBP has indicated late July 2026, but the date and scope are subject to the government's pending Federal Circuit appeal of the CIT's universal-refund order. Monitor CBP's CAPE announcements — and protect liquidated entries with a timely § 1514 protest rather than waiting.

How much money is in Phase 3?

Approximately $11.4 billion in IEEPA duties sits in finally liquidated entries — the smallest of the three phases, compared with $28.7 billion in Phase 2 reconciliation-flagged entries and the $94.9 billion accepted into CAPE overall.

Refund Programs

What is CAPE Phase 3?

The expected final CAPE phase for finally liquidated entries (~$11.4B), anticipated late July 2026 and contested in the government's Federal Circuit appeal. In the context of U.S. customs and tariff recovery, understanding cape phase 3 is essential for navigating the CAPE refund process and ensuring accurate duty assessment.

Definition

CAPE Phase 3 is the expected final expansion of the Consolidated Administration and Processing of Entries program, covering entries that have been finally liquidated — approximately $11.4 billion in IEEPA duties. CBP has indicated Phase 3 is expected in late July 2026. Its scope is contested: the Department of Justice is appealing the Court of International Trade's universal-refund order at the Federal Circuit, and depending on the outcome, Phase 3 could be narrowed to importers who filed their own CIT suits rather than covering all affected importers.

How CAPE Phase 3 Relates to Tariff Refunds

Phase 3 matters for importers whose entries liquidated before they could file through Phases 1 or 2. Because Phase 3's final shape depends on pending litigation, the protective move for a finally liquidated entry is a protest under 19 U.S.C. § 1514 within 180 days of liquidation — that preserves the claim regardless of how the appeal resolves. Tariffi tracks both clocks for every liquidated entry: the 180-day protest window and Phase 3 eligibility as CBP defines it.

Example

An importer's entries liquidated in March 2026, before CAPE launched their eligibility path. Rather than waiting for Phase 3, their broker files § 1514 protests inside the 180-day window to lock in the claims. If Phase 3 opens broadly in late July, the entries ride the CAPE path; if the Federal Circuit narrows it, the timely protests still preserve recovery.

Frequently Asked Questions

When will CAPE Phase 3 launch?: CBP has indicated late July 2026, but the date and scope are subject to the government's pending Federal Circuit appeal of the CIT's universal-refund order. Monitor CBP's CAPE announcements — and protect liquidated entries with a timely § 1514 protest rather than waiting.
Will Phase 3 cover every finally liquidated entry?: That is the contested question. The CIT ordered universal refunds, but DOJ is appealing, and Phase 3 could be narrowed to importers who filed their own CIT suits. A § 1514 protest filed within 180 days of liquidation preserves your claim either way.
How much money is in Phase 3?: Approximately $11.4 billion in IEEPA duties sits in finally liquidated entries — the smallest of the three phases, compared with $28.7 billion in Phase 2 reconciliation-flagged entries and the $94.9 billion accepted into CAPE overall.

Legal References

19 U.S.C. § 1514 — Protests (protective filing path)
CBP CAPE Program FAQ — Phase 3 (expected late July 2026)

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