What does 'Filer of Record' mean?
Quick answer
The Filer of Record is the CBP-licensed customs broker whose name, license number, and ABI filer code appear on a CAPE declaration or protest filed with CBP. The Filer of Record bears professional responsibility for the filing under 19 CFR Part 111. At Tariffi, the broker partner is always the Filer of Record — we prepare data but never file.
Detailed Answer
"Filer of Record" is a critical concept in customs law that defines who is legally responsible for a filing with CBP.
What the Filer of Record does:
- Signs and transmits the CAPE declaration or protest through the ACE portal using their ABI (Automated Broker Interface) filer code.
- Bears professional responsibility for the accuracy and completeness of the filing under their customs broker license per 19 CFR Part 111.
- Responds to CBP inquiries (Form 28, Form 29) related to the filing.
- Is subject to CBP audit on the filing.
Why this matters for Tariffi:
Under 19 U.S.C. § 1641, only a CBP-licensed customs broker can be the Filer of Record on customs transactions (including CAPE declarations). Tariffi is not a customs broker — we are a data-preparation platform. Our broker partners are always the Filer of Record on every filing that goes through our platform.
This is by design, not by limitation:
The Filer of Record distinction protects everyone involved:
- For you (the importer): Your filing is backed by a licensed professional who stakes their license on its accuracy.
- For the broker partner: Their professional role and judgment are preserved — they are not rubber-stamping automated output.
- For Tariffi: Operating as data-preparation software (not a broker) keeps us compliant with § 1641 and avoids the $10,000/transaction penalty for unlicensed customs business.
The broker partner's Filer of Record responsibilities include:
- Reviewing all CAPE declaration data before filing
- Applying professional judgment on 10-digit HTSUS classifications
- Approving or modifying entries based on their expertise
- Transmitting via their own ACE account
- Responding to CBP post-filing correspondence
This architecture follows CBP Ruling HQ H326926, which describes the legitimate partnership between a technology platform and a licensed customs broker.
Related Questions
Will Tariffi file anything under my license?
No. Tariffi is a data-preparation platform — we never access CBP servers or file anything under your license. You review every CAPE declaration in your broker portal, approve it with your professional judgment, and transmit it via your own ABI filer code through ACE. You are always the Filer of Record.
Do I need a customs broker for a tariff refund?
Yes. Federal law (19 U.S.C. § 1641) requires a CBP-licensed customs broker to file CAPE declarations. Tariffi is a data-preparation platform, not a broker — we prepare your declaration data and route it to a licensed broker partner who reviews, approves, and transmits under their own ABI filer code at no extra cost to you.
How does the Tariffi broker partnership work?
Tariffi prepares CAPE declaration data from importers' ES-003 files and routes it to your broker portal for review. You remain Filer of Record on every filing under your own ABI filer code. Tariffi never touches CBP servers. You earn a flat per-filing filer integration fee per 19 CFR § 111.36(c) — never a percentage.
What is a Limited Power of Attorney (LPOA)?
An LPOA authorizes a licensed customs broker to act on your behalf for specific customs transactions — in this case, filing CAPE declarations. You sign the LPOA directly with the broker partner (not with Tariffi) during intake. It is limited in scope to CAPE filings and does not give the broker authority over your other customs business.
Need help?
Upload your ES-003 to see how much you could recover, or talk to our team.