CAPE Pre-Filing Checklist: 9 Days to Get Ready for the April 20 Launch

Informational only — not legal advice.

What is CAPE and what does Phase 1 cover?

CAPE (Consolidated Administration and Processing of Entries) is CBP's ACE-based workflow for processing IEEPA tariff refund claims. It replaces the entry-by-entry protest/PSC approach with a consolidated declaration filed through a new tab in the ACE Secure Data Portal. CBP described the four-component architecture in a March 12, 2026 court declaration and confirmed Phase 1 details on April 10, 2026 via CSMS #68315804. (CBP declaration, Mar. 12, 2026, CBP CSMS #68315804)

Entries covered in Phase 1 (~63% of total IEEPA entries)

Phase 1 is accessible for entries that meet all of these criteria:

• Entry summary status = "Accepted" and Control Status = "CBP"
• At least one IEEPA Chapter 99 HTS line on the entry
• Entry falls into one of these liquidation states:
  • Unliquidated (not yet finalized by CBP)
  • Liquidated within the past 80 days (eligible for 90-day voluntary reliquidation under 19 U.S.C. §1501)
  • Suspended, Extended, or Under Review (included per the April 10 CSMS guidance)
  • Warehouse withdrawal entries

Entries deferred to later CAPE phases (no announced timeline)

Phase 1 does not cover:

• Entry Type 09 (Reconciliation) — including entries flagged for reconciliation
• Entry Type 08 (Duty Deferral)
• Entry Type 23 (Temporary Importation under Bond)
• Entry Type 47 (Drawback) and entries designated on drawback claims
• Entries with open protests
• Entries not filed in ACE (non-ABI entries)
• Entries subject to AD/CVD with pending liquidation instructions from Commerce
• Finally liquidated entries (outside the 90-day reliquidation window, no open protest)
• Entries with outstanding non-IEEPA bills
• Entries requiring complex interest calculations

If your most important entries fall into an excluded category, a later CAPE phase will be required. CBP has not announced timing or mechanics for those phases. (CBP CSMS #68315804)

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Checklist item 1 — Verify ACH is set up in ACE (do this first)

This is the single biggest failure point. CBP made electronic ACH refunds mandatory effective February 6, 2026, eliminating paper checks entirely. (CBP — ACE Portal and ACH Refunds FAQs) When CBP reliquidates an entry under CAPE, it routes the refund electronically to the bank account on file. If no bank account is registered — or if the account information is wrong — CBP places the refund in reject status, holding it until the importer updates the information and notifies CBP. Payment is delayed indefinitely; the funds are not lost, but they are not released.

How to verify ACH enrollment in ACE:

1. Log in to your ACE Secure Data Portal account at ace.cbp.gov.
2. Select the Importer sub-account view linked to your IOR number (not the broker view, even if you are a broker — you need the Importer view to manage ACH for the IOR).
3. Open the "ACH Refund Authorization" tab.
4. Click "Get Info/Refresh" to check whether bank account information is on file.

Requirements for the bank account:

• Must be a U.S. bank account that supports FedACH payments (NACHA-compliant)
• Non-U.S.-based importers must use a qualifying U.S. correspondent account
• The CBP Form 5106 (Importer of Record record) must be current and include a valid email address — CBP uses it for authentication

If no ACH information is on file: enroll before April 20. Instructions are in CBP's Electronic Refund Enrollment One-Pager. (CBP — ACE Portal and ACH Refunds FAQs)

Scale context: As of late March 2026, approximately 26,664 importers had completed ACH enrollment, covering roughly 78% of entries and approximately $120 billion in IEEPA duties — but that still leaves a large share of importers who have not enrolled. (CBP court filings, Mar. 2026)

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Checklist item 2 — Confirm IOR status and ACE account access

Only the Importer of Record (IOR) shown on the entry summary can file a CAPE Declaration (or authorize a broker to file on their behalf). Refunds are routed to the IOR or a Form 4811 designee — not to the buyer, consignee, or any party that economically bore the tariff cost through a price pass-through. (CBP CSMS #68315804)

Verify before April 20:

• Confirm the IOR number on your ACE account matches the IOR shown on the Form 7501 entry summaries for entries you plan to include
• Confirm your ACE account has the Importer sub-account view active (required to access the CAPE tab; broker-only accounts may not have it)
• Confirm at least one user on the account has permissions to access the new CAPE tab

If you are not the IOR but economically paid the tariff: your refund rights turn on private contract terms and the specific facts of your relationship with the IOR. The CAPE portal itself does not resolve standing questions. Confirm the entry papers first, then consult trade counsel if needed.

For a deeper discussion of IOR vs. consignee standing, see IOR vs Consignee: Who Has Standing?.

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Checklist item 3 — Gather entry numbers for eligible entries

The CAPE Declaration is, at its core, a list of entry summary numbers. Nothing else is included in the CSV. This means getting your entry numbers right is the entire pre-filing task.

Entry types to collect:

• Unliquidated entries: entries in your ACE account with no liquidation date. These are the highest-priority — they will be liquidated at the corrected (lower) amount, so IEEPA duties are permanently removed before final assessment.
• Recently liquidated entries (within 80 days): entries liquidated between approximately January 31, 2026 and today may still fall within the 90-day voluntary reliquidation window under 19 U.S.C. §1501. These will be reliquidated and the IEEPA portion refunded.
• Suspended/Extended/Under Review entries: include these — they are in scope per the April 10 CSMS guidance.

How to pull your entry numbers:

• From ACE: run an entry summary query filtered to IOR + date range (IEEPA duty period = approximately February 4, 2025 through February 24, 2026) and filter for at least one Chapter 99 HTS line
• From your customs broker: request a full entry list with liquidation status, filtered to IEEPA HTS codes
• From Form 7501 PDFs: the entry number is in Block 3 ("Entry No.") on the form (CBP Form 7501 overview)

Practical tip: build a spreadsheet with entry number, entry date, liquidation status, and liquidation date (if applicable). This doubles as your backup documentation and helps you prioritize which entries go in which declaration.

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Checklist item 4 — Understand the CSV format and 9,999-entry limit

The CAPE Declaration is a CSV file containing only entry summary numbers. CBP will not require duty amounts, HTS codes, dates, or any additional fields — just entry numbers. (CBP — ACE Portal CAPE Declarations Quick Reference Guide)

Key filing mechanics:

• 9,999 entries per declaration. If you have more eligible entries, file multiple declarations sequentially. There is no stated limit on the number of declarations per IOR.
• Download the template first. The CAPE Declaration CSV template will be available through the "Upload" button in the CAPE tab starting April 20. Use CBP's template, not a blank CSV — column headers must match exactly.
• No duplicates. A single entry number may appear only once per CSV file.
• File validation happens in two stages:
  1. File-level validation — CBP confirms the file is properly formatted, not corrupted, and the filer is the IOR or an authorized broker. If this fails, the entire declaration is rejected.
  2. Entry-level validation — CBP checks that each entry number exists in ACE and has at least one IEEPA Chapter 99 HTS number. If an individual entry fails, that entry is removed and the rest of the declaration continues processing.

Implication: a small number of ineligible entries in your CSV will not kill the whole declaration — they will simply be removed. But a formatting error in the file itself will reject everything. Double-check your CSV structure before uploading.

For ACE access: the CAPE tab will appear in your ACE Secure Data Portal account (both importer and broker accounts) starting April 20. Filing is through the portal interface only — not through ABI (Automated Broker Interface). (CBP CSMS #68315804)

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Checklist item 5 — Verify broker authorization if filing through a customs broker

Brokers may file CAPE Declarations on behalf of importers, but the authorization check is automatic and strict. There is no separately-filed power of attorney document required for CAPE beyond the normal broker authorization that was in place when the original entries were filed — but that authorization must still be in force. (CBP CSMS #68315804)

ACE enforces these rules automatically:

• The first three characters of each entry number in the broker's CSV must match the broker's ACE Filer Code
• The IOR number on the broker's ACE account must match the IOR of record for each submitted entry
• A broker filing on behalf of multiple IORs must file separate declarations — one per IOR

What this means in practice:

• If you used multiple brokers across different entries, each broker files their own declaration covering only the entries they filed
• If you changed brokers during the IEEPA period, entries from the prior broker cannot be included in the current broker's declaration — the original filer (or the IOR directly) must cover those entries
• Confirm with each broker whether they are set up to file CAPE Declarations and whether they have access to the required ACE account permissions before April 20

If your broker is not set up or not planning to file: you can file directly as the IOR if you have ACE Importer account access. Review the ACE portal setup requirements at CBP — IEEPA Duty Refunds.

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Checklist item 6 — Check Form 4811 designee status

CBP Form 4811 ("Special Address Notification") lets the IOR designate a third party — typically a customs broker, trade attorney, or other agent — to receive the refund payment on the IOR's behalf. Refunds are consolidated by liquidation/reliquidation date and routed to the IOR or the Form 4811 designee on file. (CBP declaration, Mar. 12, 2026)

Verify before April 20:

• If you want refunds paid directly to a broker or attorney, confirm a current Form 4811 is on file with CBP naming that party as designee
• The designee's bank account must also be enrolled in ACH — a Form 4811 without ACH enrollment at the designee will still result in a rejected refund
• If you want refunds paid directly to the IOR's bank account, no Form 4811 is required — but your own ACH enrollment must be current (see Checklist item 1)
• If you are a broker who advances duties and wants to receive refunds on behalf of importers, confirm that each affected IOR has a current Form 4811 designating your firm and that your ACE broker account has ACH on file

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What happens after you file

Once CBP accepts your CAPE Declaration, here is the expected timeline:

• Acceptance: ACE validates the CSV at the file and entry levels. Ineligible entries are removed. CBP assigns an acceptance date.
• Review and processing: CBP has up to 45 days from acceptance to review and liquidate/reliquidate the validated entries. Liquidation/reliquidation processing runs Monday through Thursday each week.
• Refund:
  • For reliquidated entries (recently liquidated): the IEEPA overpayment is refunded electronically via ACH, consolidated by liquidation date and IOR.
  • For unliquidated entries: CBP removes the IEEPA HTS lines, recalculates duties, and liquidates at the corrected amount — no immediate cash refund, but no future IEEPA duty owed.
  • For suspended/extended/under review entries: liquidation status is maintained with the IEEPA component removed; refund issues at liquidation.

Total time from CAPE Declaration acceptance to refund receipt for reliquidated entries: approximately 60–90 days, unless a compliance issue requires further review.

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Entries outside Phase 1: preserve your rights now

If you have finally liquidated entries (liquidated more than 90 days ago, no open protest), Phase 1 does not cover them. CBP has not announced a timeline or mechanism for those entries.

Recommended actions while you wait:

• Calendar the 180-day protest deadline from liquidation date for each finally liquidated entry (the standard protest window under 19 U.S.C. §1514) — if a later CAPE phase does not materialize before your deadline, a protest may be your only available remedy
• Confirm with trade counsel whether filing a protest now to preserve rights would conflict with anticipated CAPE participation

See also: Deadlines: Liquidation + the 180-Day Clock.

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Frequently asked questions

I filed entries through multiple brokers. Who files the CAPE Declaration?

Each broker may only include entries they originally filed (matched by filer code). You will need to coordinate with each broker separately, or file directly as the IOR for entries where the broker is unavailable. A single CAPE Declaration cannot mix entries from multiple filer codes.

Do I need to calculate the refund amount in the CSV?

No. The CSV contains only entry numbers. CBP calculates the refund amount based on its own ACE data — you do not submit a dollar figure.

What if an entry is on the list but CBP rejects it at the entry-validation stage?

That entry is removed from the declaration, but the rest of the entries are processed. You may be able to include it in a subsequent declaration or address it through a different mechanism (protest, later CAPE phase) depending on why it was excluded. CBP will provide a reason for each rejected entry.

Can I file multiple CAPE Declarations?

Yes. There is no stated limit on the number of declarations per IOR or per broker. File as many as needed to cover all eligible entries, subject to the 9,999-entry limit per declaration.

Does filing a CAPE Declaration waive my protest rights?

CBP has not indicated that CAPE participation waives protest rights, but the interaction between CAPE acceptance and existing protest deadlines is an area where trade counsel guidance is warranted, particularly for entries with tight 180-day protest windows. (CBP — IEEPA FAQ)

What about entries where a carrier or express brokerage is the IOR?

If a carrier's brokerage was the IOR and advanced duties, the CAPE refund is paid to that party. Whether and how it flows downstream to the shipper or consignee depends on the carrier's policies and contractual terms — not the CAPE portal itself. Confirm directly with your carrier.