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CAPE Phase 3 is now open for select importers of finally liquidated entries. Follow the timeline, check your deadlines, work through the readiness checklist, and estimate what a refund could be worth after fees.
IEEPA Tariff Timeline
On June 29, 2026
On April 20, 2026
On April 20, 2026
Checklist
CAPE Phase 3 is now open. Work through these seven steps now so your business is ready to file and so no deadline slips while you wait.
tHE fINANCIAL pICTURE
Total refunds accepted into CAPE processing (as of Aug 21, 2026)
Already completed and sent to Treasury
Total Entries Subject to IEEPA Tariffs
Our Process
Our process has no upfront retainer or payment.
Invoiced after we deliver your refund.
Identify and quantify entries that are finally liquidated and eligible under Phase 3 across your entry portfolio.
Assess whether filing a CIT action makes financial sense and coordinate with your legal counsel.
Prepare and file CAPE declarations correctly and in the correct sequence to protect both automated and administrative recovery paths.
Track CBP guidance, CIT rulings, and the DOJ appeal so your business isn’t caught off guard by the next change.
No Upfront Cost — Success-Fee Based
Prefer email? Tell us about your imports and the IEEPA duties you paid for a free refund estimate and eligibility review.
contact-us@leyton.com
A COST-BENEFIT LENS
Phase 3 access currently runs through the Court of International Trade. Filing suit is one way in, but it isn’t free, so claim size matters. Enter your estimated claim value to see a range of typical industry service fees and your potential net recovery, so you can judge whether filing is worth it. With Leyton, there’s no upfront cost. You’re invoiced only after we deliver your refund.
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Leyton helps businesses navigate IEEPA tariff refund with support from experienced lawyers and trade experts. We assess import and export activities, manage compliance and documentation, and work with authorities to help reduce tariff exposure and operational burden.
FAQs
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In 2025, the U.S. imposed tariffs under the International Emergency Economic Powers Act (IEEPA) on certain imported goods. In February 2026, the Supreme Court ruled these tariffs unconstitutional, and the U.S. Court of International Trade confirmed in March 2026 that importers who paid these tariffs may now be eligible for refunds plus interest.
CBP’s automated tool, built inside the ACE Secure Data Portal, processes IEEPA duty refunds at scale, rather than case-by-case manual reliquidation.
Full Refund + Interest: Removes all IEEPA duties from an entry and pays statutory interest on the amount collected.
Filed as a Declaration: Importers/brokers submit a CAPE Declaration — a list of entries, up to 9,999 per file — no other data required by CBP.
Rolled Out in Phases: CBP is deploying capability in stages (Phase 1, 2, 3) rather than opening the full population of entries at once.
Possibly, but it isn’t automatic. Entries more than 80 days past liquidation are “finally liquidated,” which means CBP can no longer reopen them on its own. That is why Phases 1 and 2 don’t cover them. You still have a few routes. Phase 3 is open to plaintiffs with a pending Court of International Trade case and a valid Importer of Record number submitted by July 30, 2026. If an entry is still within 180 days of liquidation, you may be able to file a protest. If you don’t have a case, filing suit at the CIT may still be possible, generally within two years of paying the duties. The government’s pending appeal could change who qualifies, so waiting carries risk.
Phase 3 access currently runs through the courts, so costs can include legal fees for filing and managing a CIT case, on top of any recovery-service fees. How much that matters depends on your claim size. A ~$10,000 legal bill can consume most of a ~$15,000 refund, but it is a small share of a $1M+ refund. With Leyton, there are no upfront professional fees, and you pay only when you receive your refund. Because the right approach depends on your entries and claim size, a Leyton global trade specialist can review your claim and prepare a custom proposal.
Our trade expert review your import data to:
-Identify unliquidated, liquidated, and finalized entries
-Verify tariff codes and payment amounts
-Determine the fastest and most compliant refund path
This ensures no eligible refunds are overlooked.