How to File a CAPE Declaration: Step-by-Step Walkthrough

Informational only — not legal advice.

Before you start

Two things must be in place before your CAPE Declaration can result in a refund. Getting them wrong delays payment, not eligibility:

1. ACH banking information enrolled in ACE. CBP will hold any refund amount until banking information is on file. If no ACH account is enrolled when your refund is ready, CBP holds the payment until you add it. See our ACE ACH Setup Guide for the step-by-step enrollment process.

2. Your entries are Phase 1 eligible. Not all entries qualify in Phase 1. Confirm eligibility before building your CSV — including ineligible entry numbers wastes a filing and may trigger unnecessary Stage 2 rejects.

If you haven't done the preparation work yet, start with the CAPE Pre-Filing Checklist before proceeding.

Phase 1 eligibility: what entries qualify

CAPE Phase 1, launching April 20, 2026, covers the following entry types per CBP CSMS #68315804:

Eligible for Phase 1:

• Unliquidated entries (status: Accepted, Control Status: CBP)
• Entries liquidated within the preceding 80 days — this corresponds to the voluntary reliquidation window under 19 U.S.C. §1501
• Entries with "Suspended," "Extended," or "Under Review" liquidation status
• Warehouse entries and warehouse withdrawal entries

Excluded from Phase 1 (deferred to later phases):

• Entries with unliquidated antidumping/countervailing (AD/CVD) duties with pending Department of Commerce liquidation instructions
• Entries flagged for reconciliation (type 09)
• Entries with active drawback claim designations
• Entries with open protests
• Finally liquidated entries beyond the 80-day window
• Entries not filed in ACE

CBP has estimated Phase 1 covers approximately 63% of IEEPA-affected entries. If your entries fall into an excluded category, do not wait on CAPE — consult your broker or trade counsel about existing remedies (protest, PSC) while Phase 2 guidance is pending. See PSC vs Protest: Which One Applies? for those paths.

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Step 1: Log into ACE and navigate to the CAPE tab

1. Go to the CBP ACE Secure Data Portal and log in with your ACE credentials.
2. From your account dashboard, look for the new CAPE tab. CBP added this tab specifically for IEEPA refund filing — it appears in both Importer accounts and Filer/Organizational Broker accounts starting April 20, 2026.
3. If you don't see a CAPE tab, verify your account type. Only Importer, Filer, and Organizational Broker account types have CAPE access. A stand-alone ACH/banking account sub-account does not include the CAPE filing tab.

If you're a broker filing on behalf of an importer: your account must be the same account that filed the original entry summaries. Your ACE Filer Code (the first 3 characters of the entry numbers you handle) must match the entries in your CSV — this is checked in Stage 1 validation.

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Step 2: Download the CAPE upload template

Inside the CAPE tab, there is a button or link to download the official CSV upload template.

• Download this template before building your entry list. Do not create your own CSV from scratch.
• The template has a single data column for entry summary numbers. CBP confirmed that it "will not require any other information in the .CSV file." (CBP CSMS #68315804) CBP retrieves all other entry data — duty amounts, HTS codes, IOR, port, dates — from its own ACE records.
• Save the completed file in CSV (Comma delimited) (*.csv) format. Do not save as Excel (.xlsx), or the upload will fail.

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Step 3: Populate the CSV with entry summary numbers

This is the core data preparation step. Each row in the CSV is one entry summary number.

Entry number format

CBP entry summary numbers follow the format: FFF-NNNNNNN-C

• FFF — 3-character Filer Code (assigned to the customs broker or importer who filed the entry)
• NNNNNNN — 7-digit entry number
• C — 1-digit check digit

Total: 11 characters. Entry numbers appear on CBP Form 7501 (Box 3) and in ACE entry summary exports. If you need to retrieve them, see ACE Exports Field Guide.

Limits and batching

• Each CAPE Declaration is capped at 9,999 entries.
• If you have more than 9,999 eligible entries, split them across multiple declarations. You may file as many declarations as needed.
• No duplicate entry numbers within a single file.
• An entry number already on a previously accepted CAPE Declaration cannot be included in a new one — ACE will reject it.

Quality checks before upload

Before uploading, review your list for these common issues:

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Step 4: Upload the CSV

1. In the CAPE tab, click the Upload button.
2. Select your saved CSV file from your local machine.
3. Complete the certification step that appears within the upload flow. This is a required attestation — you are certifying that the entries listed are eligible for IEEPA refund processing.
4. Submit.

After submission, ACE immediately begins Stage 1 validation.

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Step 5: Stage 1 validation — file-level check

Stage 1 runs automatically the moment you submit. It validates the entire file before any individual entry is processed.

Stage 1 checks (all of these must pass for the file to be accepted):

• File is a properly formatted CSV
• Required information is complete
• No duplicate entry numbers within the file
• Filer authorization: the submitter is either the IOR for the listed entries or the authorized customs broker that filed those entries on the IOR's behalf
• Filer Code match: the first 3 characters of every entry number in the file must match the ACE account's Filer Code
• IOR match: the IOR number associated with the submitting ACE account must match the IOR on the submitted entry summaries
• No entry numbers from previously accepted CAPE Declarations

If Stage 1 fails: ACE rejects the entire declaration. No entries are processed. You receive error notice(s) identifying what to fix. Correct the issues and resubmit the entire file. Nothing is accepted or partially credited until a Stage 1-clean file is submitted.

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Step 6: Stage 2 validation — entry-level check

Stage 2 runs only after Stage 1 passes. ACE validates each entry summary number individually.

Stage 2 checks (per entry):

• Entry summary number exists in ACE
• At least one IEEPA HTS Chapter 99 number was declared on the entry
• Entry status is eligible for Phase 1 processing (see eligibility list above)

If Stage 2 fails for a specific entry: ACE removes that entry from the declaration but continues processing all other entries in the file. Valid entries proceed; invalid ones are excluded. You can view the results — accepted vs. rejected entries with specific rejection reasons — in the CAPE tab.

Rejected entries may be resubmitted in a new CAPE Declaration after correcting the issue (where possible). See What to do if entries are rejected below.

Once Stage 2 completes: CBP accepts the CAPE Declaration. The accepted entries move into CBP's mass processing pipeline.

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Step 7: What happens after submission

After your CAPE Declaration is accepted, CBP's system processes entries through three stages automatically. You do not take action in this phase.

Stage A: Mass processing (automated duty recalculation)

ACE automatically removes the IEEPA HTS Chapter 99 duty line(s) from each accepted entry and recalculates duties as if no IEEPA tariff had applied. Interest on the refund amount is also computed automatically at this stage.

This affects only the IEEPA duty layer. Section 232, Section 301, Section 122, and other duties on the same entry are not changed. (CBP CSMS #67834313)

Stage B: Review and liquidation/reliquidation (up to 45 days)

CBP has up to 45 days from the date of CAPE Declaration acceptance to review and liquidate each entry. (CBP CSMS #68315804)

• Liquidations run Monday through Thursday only (not Friday or weekends).
• CBP retains the right to manually review individual entries before liquidation if compliance concerns arise. A compliance hold will delay the 45-day target for those specific entries.
• Entries with "Suspended," "Extended," or "Under Review" status have IEEPA HTS codes removed and duties recalculated, but follow their normal liquidation schedule rather than the 45-day track.
• Warehouse and warehouse withdrawal entries are processed similarly to suspended/extended entries.

Stage C: Refund aggregation and ACH payment (60–90 days total)

After liquidation, CBP consolidates refunds in the ACE Collections module by:

• Importer of Record (or the party designated on CBP Form 4811 as authorized notify party)
• Liquidation date

Consolidated refunds are transmitted electronically via ACH to the bank account on file in ACE.

Timeline: Valid IEEPA refunds are generally expected within 60–90 days of CAPE Declaration acceptance. (CBP CSMS #68315804)

If no ACH account is enrolled: CBP holds the refund. It will not mail a check. The payment is released only when you add banking information to your ACE account. If you haven't set up ACH yet, do it now — see the ACE ACH Setup Guide.

Form 4811 / alternate payee: If the IOR previously filed CBP Form 4811 designating a licensed customs broker as the authorized notify party, and that broker is ACH-enrolled, CBP may route the consolidated refund to the broker's account on the IOR's behalf. Confirm Form 4811 status with your broker before the CAPE Declaration is submitted.

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Common errors and how to fix them

Stage 1 errors (entire file rejected)

Filer Code mismatch

• Symptom: ACE rejects the file; first 3 characters of entry number(s) don't match your Filer Code.
• Fix: Remove entries that don't belong to your filer account. If you're a broker, confirm you're using the correct ACE account (the one that originally filed those entries).

IOR mismatch

• Symptom: ACE rejects the file; IOR on entries doesn't match the IOR associated with your ACE account.
• Fix: Segment your entries by IOR and file separate declarations per importer. If you're an importer filing directly, confirm that your ACE account's IOR number matches what's on the entry papers.

Duplicate entry numbers

• Symptom: ACE rejects the file.
• Fix: Sort the CSV, find and remove duplicates, resubmit.

Entry already on accepted CAPE Declaration

• Symptom: ACE rejects the file.
• Fix: Remove the already-accepted entry number(s) from the new file. You cannot amend an accepted CAPE Declaration — the refund for that entry is already in progress.

Corrupted or malformed CSV

• Symptom: Upload fails or ACE rejects with formatting error.
• Fix: Use the CBP-provided template. Resave in "CSV (Comma delimited) (*.csv)" format using Excel or a text editor. Do not save as .xlsx or tab-delimited.

Stage 2 errors (individual entries removed)

Entry not found in ACE

• Cause: Entry number doesn't exist in ACE — possible typo, wrong Filer Code prefix, or entry was not filed through ACE.
• Fix: Verify the entry number against your Form 7501 (Box 3) or ACE export. If the entry genuinely isn't in ACE, CAPE is not available for it; consult your broker.

No IEEPA HTS Chapter 99 number declared

• Cause: The entry summary does not include an IEEPA-specific Chapter 99 HTS code (e.g., 9903.01.25 or other IEEPA Chapter 99 lines).
• Fix: Pull the entry's HTS data from ACE or the 7501. If no IEEPA HTS was declared on the entry, there may be no IEEPA duty to refund on that entry. Confirm with your broker before resubmitting. See IEEPA HTS Codes Reference.

Entry status ineligible for Phase 1

• Cause: Entry falls into an excluded category (AD/CVD pending DOC instructions, open protest, drawback designation, reconciliation flag, or finally liquidated beyond 80 days).
• Fix: Identify the specific exclusion reason. For open protests: the protest likely already protects that entry's refund claim — do not withdraw it to file CAPE without consulting trade counsel. For drawback-designated entries, coordinate with your drawback specialist. Finally liquidated entries outside 80 days are deferred to a future CAPE phase.

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What to do if entries are rejected

After submission, review the results in the CAPE tab. ACE shows which entries were accepted, which were rejected, and the reason for each rejection.

For Stage 2-rejected entries:

1. Record the rejection reason for each entry before taking action. Different reasons require different fixes.
2. Assess whether the entry is actually eligible. Some rejections are genuine exclusions (e.g., no IEEPA HTS declared means there may be no refund available). Others are correctable (e.g., wrong entry number format).
3. For correctable entries: fix the underlying issue and include the corrected entry number in a new CAPE Declaration. There is no limit on the number of declarations you can file.
4. For excluded entries (open protest, drawback, AD/CVD, reconciliation): do not attempt to force them through CAPE. Consult your broker or trade counsel about the correct path for each exclusion type. Withdrawing an existing protest to file CAPE is potentially a serious error if the protest is protecting live refund rights.
5. For "entry not found" rejections: verify the entry exists in ACE using the entry summary search before resubmitting.

Important: Post-summary corrections (PSCs) and protests for IEEPA tariffs are automatically rejected by ACE once CAPE is the governing mechanism. Attempting parallel submissions does not protect you.

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Frequently asked questions

Can I file CAPE if I'm not the Importer of Record?

Not directly. The CAPE filer must be either the IOR or the authorized customs broker who filed the entries on the IOR's behalf. If you economically bore the tariff cost but are not the IOR, your path to the refund depends on the entry papers and any authorization from the IOR. See Who Gets the Tariff Refund?.

Can I include entries from multiple importers in one CSV?

No. Stage 1 requires the IOR on your ACE account to match the IOR on all entries in the file. Mix entries from different importers and the entire file is rejected. File a separate CAPE Declaration for each importer.

What if my entry liquidated more than 80 days ago?

Those entries are excluded from Phase 1. CBP has indicated later CAPE phases will address finally liquidated entries, but Phase 1 guidance does not cover them. Until Phase 2 guidance is published, the standard protest mechanism (within 180 days of liquidation) remains the available path. See Deadlines: Liquidation + the 180-Day Clock.

Does CAPE replace PSCs and protests?

For IEEPA tariffs specifically, ACE automatically rejects new PSCs and protests once CAPE is operational for those entries. However, entries excluded from Phase 1 (especially those with open protests) are not in CAPE yet — do not withdraw existing protests for excluded entries without advice from your broker or trade counsel.

Can I file CAPE and still get interest?

Yes. Interest on the refund amount is automatically computed by ACE as part of the mass processing step, based on the duty amounts being refunded and applicable interest rules. You don't need to claim interest separately in the CAPE Declaration.

What if I have both IEEPA entries and non-IEEPA entries?

Only include entries where IEEPA HTS Chapter 99 duties were declared. Entries with only Section 232, Section 301, or other non-IEEPA duties are not eligible for CAPE. Including them won't help — they'll be rejected at Stage 2 (no IEEPA HTS declared). See IEEPA HTS Codes Reference if you need to identify which HTS codes are IEEPA-specific.

What if my company changed brokers — who files?

The authorized filer is the broker whose Filer Code is in the original entry number. If your current broker's Filer Code doesn't match the entries, they cannot file CAPE for those entries. You'd need the original filing broker to submit, or your company to file directly as the IOR (if you have an IOR account in ACE). Confirm with your broker before April 20.

Is there a deadline to file a CAPE Declaration?

CBP has not published a CAPE filing deadline in Phase 1 guidance. However, the 80-day reliquidation window for recently liquidated entries is time-limited by statute. File those entries promptly — the window runs from liquidation date, not from when CAPE launches.

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