Except as provided in paragraph (4), a covered entity is not eligible for benefits under this section on or after the date that is 5 years after the date on which the entity is approved under subsection (d). (3) Penalty Except as provided in paragraph (4), at the end of the 5-year period under paragraph (1), a covered entity that has not completed the re-shoring or near-shoring, as the case may be, of the business of the entity shall owe to the United States— (A) the total amount of duties the entity would have owed for imports into the United States but for the application of subsection (b)