CAPE Declaration Filing Checklist: Step-by-Step Guide to Claim Your IEEPA Tariff Refund (April 2026)

# CAPE Declaration Filing Checklist: Step-by-Step Guide to Claim Your IEEPA Tariff Refund (April 2026)

U.S. Customs and Border Protection launched the Consolidated Administration and Processing of Entries (CAPE) tool at 8:00 a.m. Eastern on April 20, 2026. Three days in, the picture from the trade bar and the first wave of customs broker filings is becoming clear: CAPE works, refunds are moving, and the filers who prepared in advance are already in the queue for 60-to-90-day payment. The filers who rushed in without checking eligibility or CSV formatting are already getting declarations bounced back.

If your company paid IEEPA duties on any entry between March 2025 and February 24, 2026, you are one of the roughly 330,000 importers owed a share of approximately $166 billion in refunds. This article is the practical filing checklist — not the legal background. It covers exactly what you need to do this week to file a clean CAPE Declaration, the Power of Attorney language your broker needs, the CSV format CBP will accept, the six rejection reasons that are already dominating the first week of filings, and the one clock every Phase 1 filer needs to watch: the 80-day liquidation window.

If you want the broader legal background first, start with our IEEPA Tariff Refund Guide and the CBP CAPE Tool Launch explainer. This piece assumes you already know why the refund exists and focuses entirely on the mechanics of getting paid.

Step 1: Confirm You Are Eligible for Phase 1

Phase 1 covers a narrow slice of refundable entries. CBP structured it this way deliberately to keep the initial refund volume inside the existing 180-day protest window under 19 U.S.C. § 1514 — which means Phase 1 is legally clean and fast, but excludes a lot of entries that will have to wait for Phase 2 or Phase 3 later in 2026.

A CAPE Declaration is Phase 1 eligible if every entry on it satisfies all three of the following tests:

1. The entry contains at least one IEEPA-related HTSUS Chapter 99 code. These are the special tariff classifications CBP used to apply the 10% baseline reciprocal tariff, the country-specific IEEPA tariffs (China, Canada, Mexico, and the graduated reciprocal rates), and the IEEPA proclamations that the Supreme Court struck down in *Learning Resources v. Trump* on February 20, 2026. If an entry has no Chapter 99 IEEPA line item, there is nothing for CAPE to refund — and including it in a declaration will trigger a rejection.

2. The entry is either unliquidated or was liquidated within the preceding 80 days. Unliquidated entries (those CBP has not yet finalized) are the cleanest case. Entries liquidated within the prior 80 days are also accepted because they are still inside the 180-day protest window. Anything liquidated more than 80 days before the CAPE Declaration is submitted is deferred to Phase 2 — do not include it.

3. The entry has not already been submitted on a prior CAPE Declaration. CBP will reject any entry that appears on a previous declaration. This is the easiest mistake to make when multiple brokers or in-house trade teams file separately for the same importer of record. Lock down who is filing which entries before anyone submits anything.

If your entry fails any of the three tests, it goes on a "later phase" list. Do not try to slip it into Phase 1 — it will be rejected, and depending on how the rejection is logged, it could delay the rest of your Phase 1 filing.

Step 2: Get the Power of Attorney Right

Only the importer of record (IOR) or a licensed customs broker with a valid Power of Attorney (POA) can file a CAPE Declaration on behalf of that IOR. If you used a single customs broker for all of your 2025 entries, the existing POA you signed at the start of the relationship almost certainly covers CAPE filings — but it is worth having your broker confirm in writing before April 30.

Three POA scenarios come up most often:

Single-broker IORs. If one broker filed all of your IEEPA entries, they can file a single consolidated CAPE Declaration covering up to 9,999 entries in one submission. Existing POA language like "to transact customs business on my behalf" is broad enough to cover CAPE. Get a written confirmation from your broker that they will be filing on your behalf so you do not accidentally file twice.

Multi-broker IORs. If you used two or more brokers in 2025 — for example, one for Charleston inbound and a different one for West Coast inbound — each broker files the CAPE Declaration for the entries they originally filed. Coordinate the sequence. The first declaration sets the clock; subsequent declarations from other brokers cannot include any of the same entries without triggering a duplicate rejection. Confirm with each broker which entries they are claiming and which they are leaving to the other broker.

IOR-filed declarations (no broker). IORs that are already registered in ACE and have the ACE Portal Account Admin role can file the CAPE Declaration themselves, with no broker involvement. This is the cleanest path for larger importers with in-house trade compliance teams. The POA question does not arise; the IOR files directly. If you are going this route, confirm your ACE Portal permissions before April 30.

One new POA issue that has surfaced in the first few days of Phase 1: some IORs who changed customs brokers mid-2025 now have entries filed under the old broker's bond. Legally, the old broker still holds the POA for those specific entries, even if the commercial relationship ended. Either have the old broker file those entries, or have the IOR file directly. The new broker cannot file for entries they did not originally process.

Step 3: Pull the Entry List from ACE

The CAPE filing is built on entry numbers. Every entry you want to refund needs a verified 11-digit CBP entry number (typically in the format XXX-XXXXXXX-X). Pull the full list from ACE, not from your broker's internal system — the ACE number is the only one CBP will match on.

Inside ACE, run the "Entry Summary" report filtered by your IOR number and the date range March 1, 2025 through February 24, 2026. Export the results to CSV. Each row should contain at minimum:

- Entry number - Entry date - Liquidation status (liquidated / unliquidated) - Liquidation date (if liquidated) - IEEPA Chapter 99 HTS codes present on the entry - Total IEEPA duty amount assessed

Sort the list by liquidation status and date. Your Phase 1 eligible list is everything marked "unliquidated" plus everything liquidated on or after (today minus 80 days). As of April 23, 2026, that means liquidation dates from February 2, 2026 onward. On May 1 it will be February 10 onward. The window slides every day — entries liquidated just outside the window today will never be eligible for Phase 1, so prioritize the entries closest to falling out.

This is the single most important intuition about Phase 1: the 80-day window counts backward from the day your CAPE Declaration is filed, not from April 20. Every week you delay filing, you lose a week of eligible liquidated entries from the back of the window. If you have entries that liquidated in mid-February, file this week. Do not wait.

Step 4: Build the CAPE CSV Correctly

CBP published the CAPE CSV template as part of the April 14 CSMS guidance. The format is deliberately minimal:

Column A, Row 1: the literal header text `Entry Number` Column A, Row 2 onward: one entry number per row, in the format `XXX-XXXXXXX-X`, with no leading or trailing spaces, no quotes, and no commas or other punctuation.

That is the entire CAPE Declaration CSV. No dollar amounts, no HTS codes, no filer codes, no broker ID. CBP pulls every other data element from the ACE entry record using the entry number as the key. The filer's only job is to identify the entries.

File preparation rules that are already tripping up Day 1 filers:

- Save the file as `.csv`, not `.xlsx`. CBP's ACE upload will reject Excel files even if the data is formatted correctly. - Encode as UTF-8 without a byte-order mark. Older Excel installations write a BOM that CAPE sometimes flags. - The header row must read exactly `Entry Number`. Variations like `EntryNumber`, `ENTRY_NUMBER`, or `Entry #` all cause a file-level rejection, which kicks the entire declaration back. - No blank rows between entries. A blank row is read as an invalid entry and rejects the declaration. - No duplicate entry numbers inside the same CSV. Duplicates trigger an entry-level rejection (only the duplicate lines bounce, not the whole file), but it is cleaner to deduplicate before upload. - Maximum 9,999 entries per declaration. If you have more, split them into multiple declarations filed back-to-back.

File-level errors reject the entire CAPE Declaration and require a full resubmission. Entry-level errors only reject the offending lines — the rest of the declaration proceeds. That distinction matters enormously: a misformatted header kills the whole file, but a single ineligible entry among 5,000 valid entries only costs you that one line.

Step 5: Upload Through the ACE Portal

The CAPE upload lives inside the ACE Portal under Accounts → CAPE Declarations → New Declaration. Walk through the upload sequence as follows:

1. Log in to the ACE Portal with a user account that has the CAPE filer role. Brokers and large IORs already have it; smaller IORs may need to request it from their Account Administrator. 2. Select the filing IOR from the dropdown. Brokers filing for multiple IORs file one declaration per IOR — you cannot combine entries for different IORs in the same CSV. 3. Upload the CSV. ACE will run an immediate format check and reject with a specific error code if the file structure is bad. Fix it and re-upload. 4. Review the "Accepted for Review" confirmation page. This is not an acceptance of the refund yet — it confirms the file structure passed and the entries are queued for eligibility validation. 5. Save the CAPE Case Number. It is the sole reference for all future correspondence about the refund, including status checks, rejection notices, and ACH disbursements.

Within 24 to 48 hours, ACE produces a validation result for each entry: accepted, rejected with reason code, or pending further review. For the first wave of declarations filed April 20 and April 21, CBP is posting validation results within 12 hours — that timing will slip as volume ramps up.

Step 6: The Six Rejection Reasons You Will See Most Often

Three days of Day 1 filings have produced a consistent pattern of rejection reasons. Watch for these and pre-check your declaration against each one before uploading:

Reason 1: Entry has no IEEPA Chapter 99 HTS code. The entry exists in ACE, but no IEEPA line item was ever assessed on it. This happens when an importer includes entries from a period when IEEPA was not yet in effect on that country, or when the entry was filed under a different HTS basis. Check your ACE entry summary before adding a line to the CSV.

Reason 2: Entry liquidated more than 80 days before the filing date. The most common Phase 1 rejection. Older liquidated entries must wait for Phase 2. Cross-check your liquidation dates against the sliding 80-day window on the day you file.

Reason 3: Entry already included on a prior CAPE Declaration. Duplicates across separate declarations from different filers for the same IOR. Coordinate filing sequencing between brokers if you have multiple brokers for one IOR.

Reason 4: CSV file-level format error. Bad header, wrong file extension, extra columns, BOM encoding, or a blank row. File-level errors bounce the entire declaration. Re-save in Excel as CSV UTF-8 (comma-delimited) and re-upload.

Reason 5: Entry is under active protest or drawback claim. CBP defers these to later phases because the refund interacts with another pending action on the same entry. Pull any protested or drawback-linked entries off the Phase 1 list and handle them separately.

Reason 6: POA on file does not authorize the filer. The broker submitting the declaration does not have a current POA from the IOR on file in ACE, or the POA predates the CAPE filing and has a termination clause. Refresh the POA before filing.

Five of the six rejection reasons are preventable with a 30-minute audit of your entry list before you build the CSV. The sixth — reason 5, protests and drawback — is worth asking your broker about even if you do not think you have any, because protest flags sometimes persist in ACE after the underlying issue is resolved.

Step 7: Track the 60-to-90-Day Refund Clock

Once CBP accepts your CAPE Declaration, the refund timeline follows a defined sequence. CBP publishes the status at each step inside the ACE Portal under the CAPE Case Number:

- Day 0: CAPE Declaration uploaded and accepted for review. - Day 1–7: Entry-level eligibility validation. Accepted entries move to refund calculation; rejected entries fall off with a reason code. - Day 7–30: CBP recalculates each accepted entry, stripping the IEEPA line items and producing a final refund amount per entry and per IOR. - Day 30–60: Aggregated refund amounts move to the Treasury disbursement queue. ACH payments are scheduled against the IOR's banking information on file in ACE. - Day 60–90: ACH refund issued, with statutory interest from the original duty payment date to the refund date.

If your case exceeds 90 days without a payment, log a case inquiry in the ACE Portal. A small percentage of Phase 1 cases will get pulled into "further CBP review," typically when the original entry had any compliance flag — value reconciliation, transfer pricing questions, or anti-dumping/countervailing duty overlap. Those cases run longer but still issue a refund unless the underlying compliance issue is unresolved.

Verify that the IOR's ACH banking information in ACE is current before you file. The single biggest avoidable delay in the refund process is a bounced ACH because the banking record has not been updated since a change. If your banking changed since the original entries were filed, update ACE before uploading the CAPE Declaration.

Step 8: What to Do With Entries That Fall Outside Phase 1

About 30% to 40% of all IEEPA-affected entries will fall outside the Phase 1 window — either they liquidated too long ago, or they are tied up in protest, drawback, or FTZ admissions. These entries still qualify for a refund; they just route through a different path.

CBP has indicated Phase 2 will cover older liquidated entries (beyond the 80-day window) and is targeting a summer 2026 launch, though no firm date has been announced. Phase 3 will handle the most complex scenarios — protest-pending, drawback, FTZ, and anti-dumping overlap — and is not expected before Q4 2026.

For entries you know will be in Phase 2 or Phase 3, keep the entry records, duty amounts, and any supporting documentation accessible. Do not attempt a workaround like filing a Post-Summary Correction or a 19 U.S.C. § 1514 protest solely to force an earlier refund — CBP's guidance is explicit that IEEPA-specific refunds route exclusively through CAPE, and filing an unrelated protest may actually delay your eventual Phase 2 or Phase 3 refund.

The Bottom Line

CAPE is working. The importers filing clean declarations in Week 1 are on track for refunds inside 60 days, and the rejection patterns are predictable enough that a careful 30-minute audit eliminates five of the six most common reasons. The urgency is real, but not panic-level: the 80-day window slides daily, so every week of delay drops a handful of mid-February liquidations out of eligibility and defers them to Phase 2.

If your company paid IEEPA duties in 2025, get on a call with your customs broker this week. Confirm the POA is current. Pull the ACE entry list. Build the CSV against the exact format CBP published. File before the end of April if you have any liquidated-February entries on your list.

For the bigger picture on how current tariffs stack after the IEEPA refund — Section 301, Section 232, Section 122 — use the free Duty & Tariff Calculator to model your landed costs going forward. And if you need warehousing at the Port of Charleston while you work through the refund and restructure your import strategy, our team at Cate Freight can run the numbers — the homepage has a quote form.

The largest tariff refund in U.S. history is moving. Do not leave money on the table because a header row said the wrong thing.

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