CAPE Phase 3 opened October 6, 2026

Finally liquidated IEEPA entries now have a route to a refund.

Phase 1 and Phase 2 reach only entries that are unliquidated or liquidated within 80 days of filing. Older entries were never in scope. Phase 3 reaches finally liquidated entries through the Court of International Trade.

Tariff Refund Agency (TRA) handles the legal, and their funding partners can advance the refunds on qualified claims.

Clearview Unlimited Inc. is an Authorized Referral Partner, By Authority of Tariff Refund Agency (TRA).

IEEPA Refunds by the Numbers
$166B+
IEEPA duties collected, as of October 23, 2026
$127.7B
Sent to Treasury for disbursement, as of October 23, 2026
3,960
Phase 3 declarations accepted for processing, covering 15.8 million entries, as of October 23, 2026
Up to 95%
Of the refund advanced on qualified claims*
CBP figures per a CBP declaration filed with the Court of International Trade on October 26, 2026.
Phase 3 is open for finally liquidated entries, through the Court of International Trade.
Strictly contingency: no upfront cost.
How CAPE Works

The phase depends on liquidation status,
not on when the goods came in.

Since April 20, 2026

Phase 1

Entries not yet liquidated, and entries that liquidated within 80 days of the CAPE declaration.

Since June 29, 2026

Phase 2

Adds entries flagged for reconciliation, with the same 80-day limit.

Since October 6, 2026

Phase 3

Finally liquidated entries, through the Court of International Trade. Per a CBP declaration filed October 26, 2026, this includes finally liquidated entries subject to a protest. TRA handles the legal.

CBP typically liquidates an entry roughly 314 days after it comes in. An April 2025 entry has usually finally liquidated. A December 2025 entry may not have liquidated at all. Same importer, same duty, different route.

Already filed in Phase 1 or 2?

Congratulations, that is real money back. Phases 1 and 2 reached only unliquidated entries and entries liquidated within 80 days of filing. Entries from early-to-mid 2025 had usually liquidated well before then. They were not rejected; they were never in scope. A complimentary review shows where each entry stands.

Get a Complimentary Review
How TRA Helps

For importers, customs brokers
and trade advisors

⚖️
Primary Service

IEEPA Tariff Refund Recovery

TRA reviews the ACE entry data, prepares and audits every claim, and submits the filings in coordination with the importer's licensed customs broker. Phases 1, 2 and 3, tracked entry by entry through to payment.

  • CAPE Phases 1, 2 and 3
  • Phase 3 legal handled by TRA
  • Every entry tracked through to payment
  • Strictly contingency: no upfront cost
For Importers →  How CAPE Works →
⚡
Cash Flow

Advance Funding

On qualified claims, TRA's funding partners can advance up to 95% of the refund within 48-72 hours after claim validation and a signed funding agreement.* On Phase 3 claims, the advance also helps to pay the legal costs.

  • Up to 95% of the refund, on qualified claims*
  • 48-72 hours after claim validation and a signed funding agreement
  • No waiting on CBP for the money
Explore Advance Funding →
🤝
Partner Programs

For Customs Brokers and Referral Partners

The broker keeps the client relationship. TRA prepares the filings and submits them in coordination with the broker's desk, handles the legal on finally liquidated entries, and tracks every claim to payment.

  • The broker keeps the client relationship
  • Filings submitted in coordination with your desk
  • Built for brokers, trade advisors and logistics professionals
For Brokers →  Refer Importers →
Authorized Referral Partner · By Authority of TRA

Why work with
Tariff Refund Agency (TRA)

  • 1

    Specialists

    A dedicated team of attorneys, CPAs and licensed customs brokers focused on IEEPA refunds.

  • 2

    Platform

    Every entry reviewed, every claim audited before submission, and every claim tracked in a live portal through to payment.

  • 3

    Legal Handled

    On Phase 3, TRA handles the legal through the Court of International Trade.

  • 4

    Contingency

    Strictly contingency: no upfront cost.

Where an entry stands decides its route.

Every entry moves through liquidation on CBP's schedule. Where it stands today decides which route applies: CAPE Phase 1 or 2, a protest, or Phase 3 through the court. A complimentary review shows where each of your entries stands, entry by entry.

$0 Upfront cost. Strictly contingency.
Get a Complimentary Review
Group Sessions

See the platform live at
a weekly group session

The specialists at Tariff Refund Agency (TRA) host one live group session a day, three days a week, for importers, customs brokers, trade advisors and enterprise partners together, whichever group they come from. They demonstrate the IEEPA platform and answer questions. I join the session with everyone I introduce.

Monday
3:00 PM
Eastern Time
Wednesday
11:00 AM
Eastern Time
Friday
1:00 PM
Eastern Time
Request a Session Invite

Sessions are online. I send the invite once I have your email and best phone number.

About the Tariff Refund Agency (TRA) services on this page

Tariff refund services are provided by Tariff Refund Agency (TRA), a private consulting firm that is not affiliated with any government agency. TRA's services are strictly contingency: no upfront cost. Refund eligibility depends on each entry's status, liquidation date and other factors; recovery amounts and timing are not guaranteed. *Advance funding is provided through TRA's funding partners on qualified claims only, subject to documentation, verification, underwriting and a signed funding agreement. A CAPE declaration may be submitted only by the importer of record or the licensed customs broker that filed the entries; TRA prepares claims and coordinates their submission. CBP figures change as CBP reports.