Customs Broker CAPE Partnership Guide

Why CAPE represents a significant opportunity for brokers

The CAPE program has created a new category of customs work that did not exist before April 2026. Every importer who paid IEEPA or Section 301 tariffs on qualifying entries is a potential refund claimant. And every refund claim must be filed by a licensed customs broker. The math is straightforward: hundreds of thousands of importers, billions of dollars in overpaid duties, and a filing process that requires your license.

For brokers, this is not speculative. CAPE Phase 1 is live and processing declarations. The pass rate exceeds 97 percent. Refunds are being issued via ACH within 30 to 60 days of filing. The demand is real, the process works, and the revenue opportunity is immediate.

The challenge for many brokers is scale. Manually analyzing each client's ES-003 data, identifying qualifying entries across multiple tariff authorities and rate schedules, preparing the CAPE CSV, and managing the filing workflow across dozens or hundreds of clients is operationally intensive. This is the problem Tariffi solves: automated data preparation at scale, delivered to your desk in a format ready for your professional review and filing.

Adding CAPE refund services to your practice does not require new staff, new systems, or new regulatory approvals. You file through your existing ACE portal access using your existing license. The data preparation that would otherwise take hours per client takes minutes with Tariffi.

The revenue opportunity: flat per-filing fees

Brokers earn a flat per-filing filer integration fee for each CAPE declaration they file through the Tariffi partnership. This is a data-service fee, not a percentage of the refund amount. The distinction is legally significant under 19 CFR section 111.36 and is fundamental to the compliance architecture.

The per-filing fee is consistent regardless of the refund amount. Whether the declaration covers a small importer with a modest refund or a large importer with a substantial recovery, the broker's fee is the same flat amount per filing. This structure avoids the regulatory complications that arise when broker compensation is tied to refund outcomes.

The fee is paid by Tariffi, not by the importer. From the importer's perspective, the broker fee is included in the overall contingency fee structure. The importer pays nothing unless the refund is successfully recovered. From the broker's perspective, revenue is predictable and scales linearly with the number of filings.

For brokers with large client bases, the aggregate revenue potential is significant. If you serve 200 importers and 150 of them have qualifying entries, that is 150 filing fees for work that Tariffi has already prepared for you. The marginal effort per filing is the professional review, which typically takes one to five business days depending on the complexity and size of the declaration.

License protection: 19 CFR Part 111 and 19 U.S.C. section 1641

The Tariffi partnership is structured to protect your customs broker license, not put it at risk. Understanding the compliance architecture is critical because the regulatory framework for customs brokerage is strict, and violations can result in license suspension, revocation, or monetary penalties.

Under 19 U.S.C. section 1641, only a licensed customs broker may transact customs business on behalf of another person. Filing a CAPE declaration is customs business. This means no technology platform, consultant, or unlicensed third party can file on your client's behalf. Your license is the gatekeeper, and the Tariffi partnership respects that boundary absolutely.

19 CFR Part 111 imposes professional obligations on brokers including accuracy, diligence, and the exercise of independent judgment. When you receive a CAPE filing package from Tariffi, you are expected to review it. The package includes the entry-number CSV, a summary report, and compliance flags. Your review is substantive: you verify the entries, check the tariff authority, and confirm no disqualifying conditions exist. This is not a rubber-stamp process.

CBP Ruling HQ H326926 specifically addresses the use of technology platforms in customs data preparation. The ruling confirms that platforms may prepare data as long as the licensed broker performs the filing and exercises professional judgment. This is exactly the Tariffi model. CBP Ruling HQ H350722 further clarifies that while AI platforms may classify at the 6-digit HS heading level, all 10-digit HTSUS statistical-suffix determinations must be the broker's call. Your professional judgment is the compliance safeguard.

The Three-Party Indemnification Agreement that Tariffi prepares for each filing clarifies the responsibilities of each party: the importer warrants the accuracy of the underlying data, Tariffi warrants the accuracy of the data preparation, and the broker warrants the accuracy of the filing decision. This structure protects all three parties and is consistent with the compliance framework endorsed by CBP rulings.

How the Tariffi broker partnership works

The partnership workflow has five stages: onboarding, client referral, data preparation, broker review, and filing. Each stage has clear handoffs and responsibilities.

During onboarding, you register as a Tariffi partner broker. This involves verifying your customs broker license, confirming your ACE portal access, and establishing the filing fee arrangement. The onboarding process is straightforward and typically takes one to two business days.

Client referral works in two directions. You can refer your existing clients to Tariffi for ES-003 analysis, or Tariffi can match importers who need a broker with your practice. In either case, the LPOA is between the importer and you directly. Tariffi is not a party to the LPOA and does not receive any power of attorney.

Data preparation is Tariffi's core function. When an importer uploads their ES-003, Tariffi parses the file, identifies qualifying entries, calculates estimated refund amounts, and generates the CAPE-format CSV. The filing package is assembled and delivered to you through a secure portal. The package includes the CSV, a summary report, and any compliance flags.

You review the package, exercise professional judgment, and make the filing decision. If you approve, you upload the CSV through your ACE portal and submit the CAPE declaration. After filing, you track the declaration status and communicate results to your client. Tariffi provides status updates as they become available.

Broker onboarding: step by step

Step 1: Express interest. Contact Tariffi through the broker partnership page or through a direct referral. You will receive an overview of the partnership terms, the fee structure, and the technical requirements. Step 2: License verification. Provide your customs broker license number for CBP verification. Tariffi confirms that your license is active and in good standing.

Step 3: ACE access confirmation. Confirm that you have active ACE portal access with CAPE filing capability. If you are unsure whether your ACE account includes CAPE access, contact CBP's ACE help desk. Step 4: Agreement execution. Review and sign the Broker Partnership Agreement, which establishes the terms of the data-service relationship including the per-filing fee, confidentiality obligations, and compliance commitments.

Step 5: Portal setup. You receive access to the Tariffi broker portal where filing packages are delivered, statuses are tracked, and client communications are managed. The portal integrates with your existing workflow; it does not replace your ACE access or any other tools you use.

Step 6: First filing. Your first CAPE filing through the partnership follows the standard workflow: receive the package, review, and file. Many brokers start with one or two filings to familiarize themselves with the process before scaling to their full client base. The entire onboarding process from initial contact to first filing typically takes one to two weeks.

Communicating CAPE refund opportunities to your clients

Your clients trust you as their customs advisor. When you introduce CAPE refund services, you are extending that advisory relationship with a high-value offering that costs the client nothing unless it succeeds. The messaging should emphasize this: CAPE is a recovery opportunity that you are bringing to them proactively, with no risk and no advance cost.

Key talking points for client conversations: First, many importers do not know that tariff refunds are available through the CAPE program. Educating your clients positions you as a proactive advisor, not just a transactional filer. Second, the process starts with data they already have (the ES-003 from ACE). They do not need to gather new documentation or perform any analysis themselves. Third, the contingency fee structure means they pay nothing unless the refund is successfully recovered.

For clients who are skeptical or cautious, emphasize the compliance safeguards: the LPOA is directly with you (their existing broker), the filing goes through your ACE portal under your license, and you review every entry before submission. They are not entrusting their data to an unknown third party; they are working with their broker using a data-preparation tool.

Timing matters. Clients who file earlier generally receive their refunds sooner because CBP processes declarations on a rolling basis. Framing the conversation as time-sensitive (without being alarmist) motivates prompt action. A simple message like 'I want to make sure you capture every eligible entry before the current filing window closes' is effective.

For brokers with large client bases, a structured outreach campaign can be highly efficient. Start with your highest-volume importers (who have the largest refund potential), then work through mid-market and smaller clients. The per-client effort is low because Tariffi handles the analysis; your role is to introduce the opportunity and facilitate the ES-003 upload.

Compliance deep dive: 19 CFR section 111.36 and fee structures

19 CFR section 111.36 is the regulation that governs how customs brokers may be compensated. It prohibits arrangements where broker compensation is tied to the financial benefit of an unlicensed person in a way that effectively allows the unlicensed person to share in customs business revenue. This regulation is the reason why the Tariffi partnership uses a flat per-filing fee rather than a percentage of the refund.

The flat fee structure ensures that the broker's compensation is for a defined professional service (reviewing and filing the CAPE declaration), not for enabling a technology platform to earn a share of the refund. The broker earns the same fee regardless of whether the refund is large or small, successful or unsuccessful. This aligns the fee with the work performed, not the financial outcome.

Some brokers ask whether the overall contingency model (where Tariffi earns a percentage of the recovered refund) creates a problem under section 111.36. It does not, because Tariffi's fee is paid by the importer for data-preparation services, and the broker's fee is paid by Tariffi for professional filing services. These are two distinct service relationships with two distinct fee structures. The broker's compensation is not a split of the contingency fee; it is a separate, fixed payment for a separate service.

If you have specific compliance questions about the fee structure, we recommend consulting the regulatory text directly or discussing with CBP's Office of Trade. The partnership is designed to be transparent and defensible under the current regulatory framework.

The master ES-003 workflow for multi-client brokers

Brokers who serve multiple importers can dramatically accelerate their CAPE filing pipeline using the master ES-003 workflow. Instead of collecting individual ES-003 files from each client, you export a single master file from ACE filtered by your Filer Code. This file contains entries for all of your clients in one export.

When you upload the master ES-003 to Tariffi, the system groups entries by IOR Number (the Importer of Record identifier, derived from the client's EIN). Each unique IOR Number becomes a separate claim instance. Tariffi identifies refund opportunities for each importer individually, calculates per-client estimated refund amounts, and generates separate filing packages.

The master-file approach has several advantages. First, it is dramatically faster than collecting and uploading individual files from each client. One export, one upload, and Tariffi discovers every client's refund opportunity simultaneously. Second, it ensures completeness: you do not miss clients who might not have responded to an individual outreach. Third, it allows you to prioritize your filing pipeline by sorting clients by estimated refund amount.

After the analysis, you can review the per-client results and reach out to each importer to initiate the signing and authorization process. The clients still need to sign the LPOA and fee agreements, but the data work is already done. This workflow turns a potential multi-week client-by-client outreach process into a single-day discovery exercise.

Scaling your CAPE practice

Once you have filed your first few CAPE declarations and are comfortable with the process, scaling to your full client base is straightforward. The master ES-003 workflow handles the discovery phase. The signing and authorization phase can be managed through structured outreach. The filing phase is linear: one declaration per client, with the data already prepared.

Operational tips for scaling: Batch your reviews. Rather than reviewing one filing package at a time, schedule dedicated review blocks where you process multiple packages in sequence. The consistency of the Tariffi package format means each review follows the same checklist, which speeds up the process significantly.

Track your pipeline. The Tariffi broker portal shows the status of each client's claim: analysis complete, awaiting signatures, filing package delivered, declaration filed, CBP processing, refund received. Use this pipeline view to identify bottlenecks and follow up with clients who have not completed their signing packages.

Communicate results. When a client's refund is processed, notify them promptly. A successful refund is a powerful proof point for your advisory value and often leads to referrals. Document the refund amount and the timeline to build a track record that you can reference (with client permission) in future outreach.

Consider specialization. Some brokers find that CAPE refund services become a significant enough revenue stream to warrant a dedicated team member or workflow. Even a part-time focus on CAPE filings can produce meaningful revenue given the per-filing fee structure and the volume of eligible importers.

Addressing common broker concerns

The most common concern brokers raise is whether Tariffi competes with their brokerage. The answer is no. Tariffi is a data-preparation platform. We are not licensed, do not want to be licensed, and structurally cannot file with CBP. Your client relationship, your LPOA, and your filing authority are entirely yours. Tariffi is a tool that makes your filing work faster and more accurate.

A related concern is client poaching: will Tariffi try to redirect your clients to a different broker? No. The partnership model is designed around the existing broker-client relationship. When an importer who already has a broker engages with Tariffi, we facilitate the filing through their existing broker. We do not match them with a different broker unless they do not have one.

Some brokers worry about liability. The Three-Party Indemnification Agreement clearly allocates responsibility: the importer warrants data accuracy, Tariffi warrants data preparation accuracy, and the broker warrants the filing decision. If an entry is rejected because of a data preparation error, that is Tariffi's responsibility. If an entry is rejected because of a filing decision, that is the broker's responsibility. The allocation is clear and documented.

Finally, some brokers ask about exclusivity. The Tariffi broker partnership is non-exclusive. You are free to use other data-preparation tools, file CAPE declarations manually, or work with other platforms. The partnership adds capability to your practice; it does not restrict your options.

Technical requirements for partner brokers

The technical requirements for participating in the Tariffi broker partnership are minimal. You need an active customs broker license in good standing, ACE portal access with CAPE filing capability, and a web browser to access the Tariffi broker portal.

No software installation is required. The Tariffi broker portal is a web application accessible from any modern browser. Filing packages are delivered through the portal and downloaded as standard files (CSV for the CAPE submission, PDF for the summary report). You upload the CSV to ACE the same way you would upload any other filing.

If you manage your brokerage operations through a customs management system (TMS, customs ERP, or similar), the Tariffi filing packages integrate into your existing workflow. The CSV file is the same format regardless of whether you upload it manually through the ACE web interface or through an automated feed. Tariffi can also deliver packages via API for brokers who want deeper integration.

Data security meets the standards you expect. All data is encrypted at rest (AES-256) and in transit (TLS 1.3). Access controls restrict visibility to only the clients assigned to your brokerage. Tariffi complies with 19 CFR Part 163 record retention requirements and maintains audit logs for all filing activities.

Getting started as a Tariffi partner broker

If you are ready to add CAPE refund services to your practice, the next step is to register through the Tariffi partners page at tariffi.io/partners. The onboarding process takes one to two weeks from initial contact to first filing.

If you want to explore the opportunity before committing, you can upload a master ES-003 for a preliminary analysis. Tariffi will identify how many of your clients have qualifying entries and provide aggregate estimated refund amounts. This lets you assess the revenue opportunity before signing a partnership agreement.

For brokers who want to discuss the compliance architecture in more detail, Tariffi's compliance team is available for a one-on-one walkthrough of the fee structure, the Three-Party Indemnification Agreement, and the regulatory framework. We understand that your license is your livelihood and take the compliance conversation seriously.

Whether you serve ten importers or ten thousand, the partnership model scales to your practice. Start with a few filings, build confidence in the process, and expand from there. Your clients have money waiting to be recovered, and you are the only one who can file the claim.