September 16, 2026

U.S. Customs Update: Phase 3 IEEPA Refunds, IOR Voiding

IEEPA tariff refunds – Phase 3 launches October 6 For Early Plaintiffs

CBP has confirmed it will deploy Phase 3 of its CAPE refund program in ACE on Tuesday, October 6. This phase covers the older, finally liquidated entries that the Court of International Trade has ordered CBP to reliquidate, so it applies to importers who filed at the CIT. For importers who filed suit by July 30, you’ll be able to file Phase 3 declarations starting October 6. If your suit began after July 30, CBP says separate instructions are coming

If you didn’t file at the CIT, nothing changes for you here; Phases 1 and 2 remain the route for eligible entries.

CBP is currently sitting on more than 20,000 approved refunds, worth roughly $1.3 billion, that can’t be paid out because the importer never added banking (ACH) details in ACE. If you’re expecting a refund under any phase and haven’t set that up, please reach out to Carson for assistance.

CBP starts voiding importer of record (IOR) numbers this Friday, September 18

Beginning Friday, CBP will void importer numbers where the information on file (CBP Form 5106) is inaccurate or incomplete. A voided number can’t be used to make entry, meaning your shipment stops at the border with no advance warning.

The three things CBP is focused on: your physical business address (not a broker, forwarder, P.O. box or registered agent), an email address that belongs to your company (not a service provider), and a working phone number tied to your business. Non-resident importers and anyone who set up their IOR through a third party are the most likely to have incorrect details on file.

A voided IOR number could take more than 5 business days for the CBP to reinstate, so if you haven’t confirmed your 5106 details recently, please check in the ACE portal or contact us.