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Compare · vs DIY CAPE filing

un-tariff vs DIY CAPE filing

What filing by hand actually looks like — every CBP rule you have to run, every lookup you have to do — versus what the software automates.

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What DIY actually looks like

A CBP CAPE filing is a CSV of entry numbers. Sounds simple; the work is in knowing which entry numbers to put in the file. DIY means doing all of the following by hand:

  1. Export the ACE Entry Summary for the full IEEPA window, with Liquidation Date, paid-duty breakdown, HTS subheadings, and country of origin. (Same as the software path.)
  2. Cross-reference each line against Chapter 99. For every HTS subheading + entry-filing-date combo, look up whether that subheading was in scope of an IEEPA executive order at that time. Chapter 99 has hundreds of subheadings with overlapping effective dates — you need the full registry.
  3. Separate stacked tariffs. For lines that paid both IEEPA and Section 232/301, split the duty into buckets. Only the IEEPA bucket flows to the refund.
  4. Compute the 80-day cliff per entry. Liquidation Date + 80 days. Drop anything in the past.
  5. Walk interest daily across quarterly rate boundaries. For each entry, compound CBP's overpayment rate daily from the payment date to the refund date. The rate changes quarterly — Q4 2025 was one rate, Q1 2026 another, Q2 2026 another. Miss a boundary and the answer is off.
  6. Validate locally. CBP's VAL-F (file-level), VAL-E (entry-level), and VAL-I (identity) rules all have to pass before upload. Running them mentally is not reliable — run the checks explicitly.
  7. Generate a format-compliant CSV. UTF-8, no BOM, LF line endings, CBP's required header row from the CAPE Upload Template, 11-character CBP entry numbers, one per data row, ≤ 9,999 data rows. A spreadsheet export often ships CRLF, CR-only, or with the wrong header text.
  8. Upload, respond to validation errors, repeat.

Where DIY typically breaks

Interest-walk math

The daily-compounded interest walk is the most common error source. Spreadsheet formulas that use the Q1 rate across the full walk are off by roughly 2–5% from what CBP actually pays. The variance is not dollars — it's hundreds to thousands of dollars per large entry. When CBP's number comes back different from yours, you cannot tell whether CBP was right or the spreadsheet was.

HTS registry versioning

Chapter 99 subheadings have overlapping effective dates — an HTS code might be IEEPA-in-scope from Feb 4, 2025 to May 15, 2025, out of scope from May 16 to Aug 1, and back in scope from Aug 2 onwards. Matching the right registry row to each entry-filing-date requires versioned data. A flat "list of IEEPA HTS codes" spreadsheet gets this wrong.

Encoding and line endings

Excel on Windows saves CSV as Windows-1252 with CRLF. Excel on macOS saves as CR-only. Google Sheets saves as LF-only. CBP's CAPE validator wants UTF-8 with LF — so Windows Excel and macOS Excel both need conversion before upload. The fix is trivial but the silent failure is common — CBP's error is “malformed file” with no detail.

Cliff surprises

An entry you thought was safe has a liquidation date you forgot about. It's three days past the 80-day cliff. CAPE rejects. Now you have a protest filing to add to the list.

What the software automates

un-tariff runs the versioned registry lookup, the stacking separation, the 80-day cliff computation, the daily-compounded interest walk, and the full VAL-F/E/I validation automatically from your ACE export. What you'd do in spreadsheets over a week, it does in seconds — with every computation traced back to the rule ID and registry version that produced it. Audit trail comes built-in.

CBP's published CAPE Trade Information Notice and the IEEPA FAQ are the authoritative sources; un-tariff's rule engine implements them directly.

When DIY is actually fine

  • Fewer than ~20 entries. Manual effort is tractable.
  • All entries have clean IEEPA-only duty (no Section 232 or 301 stacking).
  • Your compliance team already tracks per-entry data with the paid-duty tranche breakdown.
  • You're comfortable with the interest walk and the HTS registry — or happy to build a spreadsheet and verify against CBP's reconciliation.

Common questions

Is DIY filing allowed?

Yes. CBP's CAPE rules do not require a licensed broker or attorney. The IOR can file directly through the ACE Portal. The software versus DIY question is about time and error rate, not permission.

What is the hardest part of DIY?

Two things: (1) classifying each entry line against the Chapter 99 IEEPA registry with the correct effective-date versioning, and (2) the daily-compounded interest walk across quarterly rate boundaries. Both are straightforward conceptually and error-prone in a spreadsheet.

Can I just put every entry number in a CSV and hope?

CBP's validation (VAL-E) will reject entries outside the IEEPA window, past the 80-day cliff, or without a matching IEEPA-classified duty line. A shotgun file fails validation and returns an error list — you spend more time reconciling rejections than you would doing the classification upfront.

When does DIY make sense?

Small importers with a handful of entries, a compliance team already tracking them, and time to work through the CBP rules carefully. For anyone with more than ~20 entries, the software's time savings exceed the flat fee.

If you'd rather skip the spreadsheet work entirely, start with the free calculator. If the refund band warrants it, the paid tool handles steps 2 through 7 automatically.

Next step

See what you can recover before you do anything else.

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