Why can't Tariffi be the Filer of Record?

Filing customs documents with CBP constitutes 'transacting customs business,' which under federal law (19 U.S.C. section 1641) may only be performed by a licensed customs broker. Tariffi prepares data; your broker files.

Can I file my own CAPE declaration?

Technically, an importer can self-file if they have direct ACE portal access. However, most importers use a licensed broker for accuracy, compliance, and efficiency.

Participants

What is Filer of Record?

The licensed customs broker who transmits entry data to CBP and bears regulatory responsibility for the filing. In the context of U.S. customs and tariff recovery, understanding filer of record is essential for navigating the CAPE refund process and ensuring accurate duty assessment.

Definition

The Filer of Record is the licensed customs broker who transmits entry data to CBP and bears regulatory responsibility for the accuracy and completeness of the filing. Under 19 U.S.C. section 1641 and 19 CFR Part 111, only a licensed customs broker (or a self-filing importer with their own ACE portal access) can serve as Filer of Record. The Filer of Record is distinct from the Importer of Record: the importer is responsible for duties and compliance; the filer is responsible for the filing itself. Most importers use a licensed broker as their filer.

How Filer of Record Relates to Tariff Refunds

For CAPE refund declarations, the Filer of Record is your licensed customs broker. Tariffi is a data-preparation platform and cannot serve as Filer of Record — this is a fundamental regulatory constraint under 19 U.S.C. section 1641. Your broker reviews the declaration data Tariffi prepares, takes responsibility for its accuracy, and transmits it through ACE.

Example

Broker ABC serves as Filer of Record for the CAPE declaration. They review the 1,000-entry CSV that Tariffi prepared, confirm the data matches their records, and submit the declaration through ACE. Broker ABC's Filer Code appears on the filing.

Frequently Asked Questions

Why can't Tariffi be the Filer of Record?: Filing customs documents with CBP constitutes 'transacting customs business,' which under federal law (19 U.S.C. section 1641) may only be performed by a licensed customs broker. Tariffi prepares data; your broker files.
Can I file my own CAPE declaration?: Technically, an importer can self-file if they have direct ACE portal access. However, most importers use a licensed broker for accuracy, compliance, and efficiency.

Legal References

19 U.S.C. § 1641 — Customs Brokers
19 CFR Part 111 — Customs Broker Regulations

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