THIS WEEK AT A GLANCE
Three important CBP developments are approaching:
- October 6: CAPE Phase 3 launches for certain finally liquidated IEEPA entries
- October 1: Merchandise Processing Fee (MPF) minimum and maximum increase
- September 18 Reminder: CBP begins voiding IOR numbers for inaccurate or incomplete importer information
Here’s what importers should know.
1 | OCTOBER 6: CAPE PHASE 3 LAUNCHES
CBP is scheduled to launch CAPE Phase 3 in ACE on October 6, creating a refund pathway for certain finally liquidated entries that were subject to IEEPA duties.
The initial process applies specifically to importers involved in applicable Court of International Trade (CIT) litigation where the Court has ordered CBP to reliquidate the entries.
Affected importers should confirm their IOR information, identify potentially eligible entries, verify ACH refund information in ACE, and coordinate with their customs broker or trade counsel before October 6.
Important: CAPE Phase 3 is not currently a blanket refund process for all importerswith finally liquidated IEEPA entries.
2 |OCTOBER 1: MPF LIMITS INCREASE
CBP’s annual Customs user fee adjustment takes effect October 1, 2026.
The MPF rate remains unchanged at 0.3464%, but the minimum and maximum amounts will increase:
| MPF | Through Sept. 30 | Effective Oct. 1 |
| Minimum | $33.58 | $34.58 |
| Maximum | $651.50 | $670.86 |
| Rate | 0.3464% | 0.3464% |
What to Watch: Importers should update landed-cost calculations to reflect the new MPF minimum and maximum beginning October 1.
3 |REMINDER: SEPTEMBER 18 IOR DEADLINE
Beginning September 18, CBP will begin voiding Importer of Record (IOR) numbers when importer information on file is inaccurate or incomplete.
Importers should make sure their Form 5106 information is accurate and current, including company information, addresses, contact details, importer/IRS information, and ownership information.
What to Watch: Inaccurate records could result in an IOR number being voided and potentially create issues with future entries and customs clearance.
PILAR’S TAKEAWAY
The next few weeks bring several important CBP deadlines.
Importers should review upcoming MPF changes, determine whether CAPE Phase 3 may apply to eligible IEEPA entries, and make sure their IOR information is accurate and up to date.
