U.S. Customs and Border Protection officially launched Phase 3 of the Consolidated Administration and Processing of Entries refund system in the early morning hours of October 6. Designed specifically to process refunds on finally liquidated entries subject to court-ordered reliquidation, the deployment represents another major step forward in clearing extensive trade-related duty refund backlogs.
By midday on launch, 477 Phase 3 declarations had already cleared initial validations, representing 425,517 eligible entries.
Key Deployment Milestones
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Targeted Scope: Phase 3 operations remain strictly reserved for finally liquidated entries linked to active Court of International Trade litigation where reliquidation has been judicially mandated.
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Notification Protocols: Legal counsel representing qualifying plaintiffs who submitted a verified Importer of Record number by the July 30 deadline have been formally notified to proceed with filings. Instructions for parties meeting verification criteria after the July cutoff will follow in subsequent operational releases.
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High Processing Volumes: Across the entire CAPE framework, 297,887 total declarations had been submitted through early October. Of those filings, 209,262 declarations successfully cleared system validations—accounting for 27.4 million individual entries and representing approximately $136.6 billion in potential and certified refunds.
Critical Compliance Considerations
While the pace of declaration intake is accelerating, strict automated screening protocols continue to enforce rigorous entry criteria. Approximately 6.2 million entries failed entry-level validations, primarily due to:
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Reliquidation Timeframes: Entry dates falling outside CBP’s 90-day statutory reliquidation authority.
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Classification Omissions: Missing applicable Chapter 99 Harmonized Tariff Schedule numbers tied to the original duty assessments.
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Duplicate Submissions: Duplicate entry numbers previously logged on prior CAPE filings.
For importers participating in court-ordered reliquidation programs, audit readiness remains paramount. Pre-submission audits should verify that all importer identification records match agency filings, tariff classifications are accurately represented, and entries fall within the enforceable bounds of the court order before submitting Phase 3 declarations.
