US Customs and Border Protection has opened Phase 3 of its Customs and Border Protection Portal — known as CAPE — for refund claims tied to tariffs imposed under the International Emergency Economic Powers Act. The announcement gives importers a fresh window to pursue recovery of duties they paid on entries affected by the IEEPA tariff regime. The precise filing deadline and claim mechanics sit with CBP's published guidance; the essential fact is that the window is now open.

For practitioners, the significance is procedural rather than doctrinal. Phase 3 extends the staged rollout that CBP has used since courts disrupted the IEEPA tariff programme, giving claimants an orderly channel rather than a scramble of ad hoc protests. The portal route matters because it standardises how refund requests are received, tracked and adjudicated.

What does Phase 3 cover?

The phase applies to refund claims for duties collected under IEEPA authorities. Importers and their brokers who paid such duties on covered entries may file through CAPE during this window. The designation of a third phase signals continued volume: CBP evidently expects a substantial queue of claims, and the portal is the mechanism for managing it.

Practical points for filing teams:

• Confirm the entry falls within the IEEPA tariff scope before filing; ineligible claims add cost without recovery.
• Assemble entry-level documentation — payment records, entry summaries, and any prior protest history — before submission.
• Track the phase deadline; a missed window invites the less comfortable machinery of protests and reconciliations.
• Coordinate between broker and counsel on who files, because duplicate filings slow everything down.

Why the IEEPA refund track exists

The refund machinery follows litigation over tariffs imposed under the International Emergency Economic Powers Act, which subjected importers to duty liabilities many now contest. CBP's phased CAPE rollout is the administrative answer: rather than resolving each dispute in isolation, the agency processes claims in cohorts. Phase 3 is the latest cohort.

One observation, offered dryly. Government refund programmes rarely multiply because claims are scarce. A third phase suggests the first two did not exhaust the demand.

What should practitioners do now?

File promptly and precisely. The portal window rewards preparation and punishes improvisation, and refund claims that arrive complete move faster than those that arrive twice. Counsel should also brief clients on documentation retention, because refund audit trails outlive the headlines that created them.

The takeaway: the window is open, the route is standardised, and importers with covered IEEPA duty payments should act within the phase rather than after it.