The complete CAPE filing guide

Overview

A CAPE filing looks deceptively simple — the deliverable is a one-column CSV of entry numbers. The work is in knowing which entries belong in the file and defending the answer with an audit trail. This guide walks through the nine steps in the order CBP's validation runs them.

The free calculator gives you the refund band before you commit to the full filing workflow. Once you're ready to file, the paid tool runs all of step 2 through step 7 automatically from your ACE export.

1. Export the ACE Entry Summary

Log in to the ACE Portal. Open Reports → Entry Summary. Filter for the date range Feb 1, 2025 – Feb 7, 2026 (the IEEPA window). Include the Paid Duty breakdown (so Section 232 / 301 amounts are visible per line) and the Liquidation Date column. Export to CSV.

The full mechanics — which screens, which filters, which fields — are in Exporting your ACE Entry Summary.

2. Classify each line against the IEEPA HTS registry

For every entry line, check the HTS subheading and the entry filing date against the Chapter 99 IEEPA registry. The registry is a versioned table that lists which HTS codes were in scope of an IEEPA executive order, with effective_from and effective_to dates keyed to the executive orders. A line qualifies only when the filing date falls inside an IEEPA-in-scope window for that HTS subheading.

Lines that were Section 232, Section 301, or ordinary column-1 duty only are dropped — they are not refundable via CAPE. They may be refundable by a different channel (court-ordered Section 301 refunds for the HMTX litigation, for example), but that is a separate process.

3. Separate stacked tariffs

Where the same entry line paid both IEEPA and Section 232 (or Section 301), the paid duty stacks — the importer paid, say, 25% Section 232 plus 10% IEEPA on the same line. Only the IEEPA portion refunds. CBP's CAPE validation will reject a filing that claims the full stacked amount.

The canonical rule is IEEPA-005 (stacking). It splits the paid duty into three buckets — IEEPA principal, non-IEEPA principal, and the applied rate — and only the IEEPA bucket flows into the refund computation.

4. Drop entries past the 80-day cliff

For each entry, compute liquidation_date + 80 days. If that date is in the past, the entry is ineligible for CAPE. Mark it for protest (out of scope for Phase 1 un-tariff; see the 80-day cliff guide) and drop it from the CSV.

Entries whose liquidation date is within 80 days of today are eligible. Entries that have not yet liquidated are also eligible, but they have a window that opens at liquidation and closes 80 days later — file them earlier to leave room for a re-submission if CBP returns a validation error on the declaration.

5. Compute principal and interest

Principal is the IEEPA-bucket amount from step 3. Interest is the CBP quarterly overpayment rate at 19 CFR 24.3a, compounded daily from the payment date of the entry to the refund-issue date. Quarterly rates are published by CBP via CSMS messages; as of Q2 2026 the rate is 8% annualized.

This is the step where spreadsheet math usually produces the wrong answer. Interest walking across quarter boundaries with rate changes is not hard, but it is fiddly, and CBP's final reconciliation runs the exact walk — so guessing produces variances that trigger review.

6. Validate against CBP CAPE rules

CBP publishes three validation rule families:

• VAL-F (file-level) — encoding, line endings, row count (≤ 9,999), no duplicate entry numbers.
• VAL-E (entry-level) — each entry exists in CBP's records, is in the IEEPA window, has a liquidation date, and has not already been refunded.
• VAL-I (identity) — the IOR, filer code, and ACH payer ID attached to the declaration match a valid, active CBP registration.

Run these locally before generating the CSV. A file that fails on upload costs you a day in the ACE Portal queue — running the same rules locally takes milliseconds.

7. Generate the CAPE CSV

Format spec (per CBP CSMS April 13, 2026 and the CAPE Upload Template):

• Single column.
• Header row matching CBP's CAPE Upload Template (verify against the current Excel template in the ACE Portal).
• 11-character CBP entry numbers: 3-char filer code + 7-digit serial + 1 check digit, matching ^[A-Z0-9]{3}[0-9]{7}[0-9A-Z]$.
• One entry per data row.
• UTF-8 encoding, no BOM.
• LF (\n) line endings.
• ≤ 9,999 data rows (excluding header).

This is the deliverable. Everything else — the principal computation, the interest walk, the stacking separation — lives in your records as documentation you can produce if CBP asks during reconciliation. The CSV itself is just the pointer.

8. Upload to the ACE Portal

In the ACE Portal, open CAPE Submission. Select the CSV. Provide your IOR number, filer code, and ACH payer ID. Submit. CBP returns an acknowledgement within 48 hours with either an accepted declaration ID or a validation error list keyed to VAL-F / VAL-E / VAL-I rules.

9. Track and reconcile

CBP targets 30–60 days from accepted declaration to ACH deposit. When the ACH arrives, compare the paid amount against your computed expected refund. Small variances (under 1%) are typically interest-day rounding differences. Larger variances warrant a reconciliation request — keep the audit trail from step 5.

Common questions