How to File a CAPE Declaration

What is the CAPE portal?

CAPE is an online system within CBP's Automated Commercial Environment (ACE) designed to process claims for tariff overpayments. The acronym stands for Customs Automated Protest and Entry, reflecting its origin as a modernized replacement for the paper-based protest process that previously governed tariff refund claims. CAPE launched in April 2026 to address the surge in refund claims created by IEEPA and Section 301 tariff modifications.

Before CAPE, importers seeking tariff refunds filed formal protests using CBP Form 19. That process required physical documentation, manual review by CBP officers, and processing times that often stretched beyond a year. CAPE digitizes the entire workflow: importers and their brokers submit structured data files, CBP validates them against internal records automatically, and refunds are processed via ACH without paper handling.

CAPE operates within the existing ACE portal infrastructure. Licensed customs brokers access CAPE through their existing ACE accounts. Importers do not have direct access to the CAPE filing interface. All declarations must be submitted by a licensed broker who is the Filer of Record for the claim. This requirement is mandated by 19 U.S.C. section 1641 and applies regardless of whether the importer has their own ACE portal access.

The system processes declarations on a rolling basis. There is no single deadline after which all claims are evaluated simultaneously. Instead, CBP reviews each declaration as it is received, validates the entries, and queues approved refunds for ACH disbursement. This rolling model means earlier filings generally receive their refunds sooner.

CAPE Phase 1 versus Phase 2

CAPE Phase 1 is the initial release of the portal, focused on the most straightforward category of tariff refund claims: entries where the IEEPA or Section 301 tariff rate has been reduced and the overpayment is calculable from the entry data alone. Phase 1 accepts a simple CSV file containing qualifying entry numbers. CBP handles the rate-differential calculation internally.

Phase 1 has a deliberately narrow scope by design. By limiting the input to entry numbers and relying on CBP's own records for validation, the system avoids the complexity of accepting external duty calculations, classification disputes, or valuation adjustments. This simplicity is why Phase 1 achieves a pass rate exceeding 97 percent: the data either matches CBP's records or it does not.

CAPE Phase 2, which CBP has announced but not yet launched, is expected to expand the scope significantly. Phase 2 may accept entries with more complex refund calculations, including entries where classification corrections or valuation adjustments affect the refund amount. It may also expand to additional tariff programs beyond IEEPA and Section 301.

For importers and brokers planning their filing strategy, the practical advice is clear: file all Phase 1-eligible entries now through the current portal. Do not wait for Phase 2 to process entries that already qualify. Phase 2 will address entries that Phase 1 cannot handle, not replace Phase 1 for entries that already fit its criteria.

The ES-003 format: required data fields

The ES-003 is the foundational data file for every CAPE declaration. It is a CSV export from the ACE portal that contains your complete entry summary history. The file format is standardized by CBP, meaning every ES-003 export from any ACE account follows the same column structure.

Key fields that Tariffi uses for refund analysis include: Entry Number (the unique identifier for each entry summary), Entry Type (which determines the tariff program), Filer Code (identifies the broker who filed the entry), IOR Number (the Importer of Record, derived from the EIN), HTS Number (the tariff classification code), Country of Origin (critical for determining which tariff program applies), Entry Date (determines whether the entry falls within the eligibility window), Duty Amount (what was actually paid), and Liquidation Date and Status (determines whether the entry has been finalized by CBP).

The ES-003 also includes Merchandise Processing Fees (MPF), Harbor Maintenance Fees (HMF), and other charges. While these are not typically part of a CAPE refund claim, they provide a complete picture of the total costs associated with each entry.

You do not need to clean, filter, or modify your ES-003 before uploading it to Tariffi. The analysis engine handles all parsing, filtering, and validation automatically. Upload the raw file exactly as ACE generates it. If the file contains entries for multiple importers (as with a broker's master export), Tariffi groups them by IOR Number and creates separate claim instances.

How to export your ES-003 from ACE: step by step

Exporting your ES-003 is straightforward but there are several details that affect the quality and completeness of your data. Follow these steps to ensure a clean export that covers your full refund opportunity.

Step 1: Log into the ACE portal at ace.cbp.dhs.gov using your portal credentials. If you have multiple ACE accounts (common for importers who work with multiple brokers), you will need to repeat this process for each account. Step 2: Navigate to the Reports section in the left-hand navigation menu. Under Entry Summary reports, locate the ES-003 export option. Step 3: Set the date range. For maximum coverage, select the broadest range that includes the period when IEEPA or Section 301 tariffs were in effect. If you are unsure of the exact dates, err on the side of a wider range. Tariffi filters ineligible entries automatically.

Step 4: Select your output format. The ES-003 is generated as a CSV file. Do not convert it to Excel format before uploading, as Excel can modify entry numbers (removing leading zeros, converting long numbers to scientific notation) and corrupt the data. Step 5: Click Generate Report and wait for ACE to produce the file. Large exports may take several minutes. If the request times out (a known ACE Business Object limitation), split your date range into smaller segments and generate multiple files.

Step 6: Download all generated files. If you split your export into multiple files, upload all of them to Tariffi. The system deduplicates entries automatically and consolidates them into a single analysis. Verify that the downloaded file opens correctly in a text editor (not Excel) and contains data rows beyond the header. An empty or header-only file indicates a date range with no entries.

For customs brokers exporting on behalf of clients: use the Filer Code filter to export a master ES-003 containing entries across all your clients. Tariffi will identify each unique IOR Number in the file, group entries accordingly, and create separate claim instances for each importer. This approach is dramatically faster than exporting individual files per client.

CAPE CSV format requirements

The CSV file that your broker uploads to the CAPE portal is not the same as the ES-003. The CAPE submission file is a simplified format that contains only the entry numbers that qualify for a refund. Tariffi generates this file automatically from your ES-003 data after the analysis and eligibility screening are complete.

The CAPE Phase 1 CSV format is intentionally simple: a single column of entry numbers with no header row required (though one is accepted). Each row contains one entry number. The entry number must match exactly the format in CBP's records, including any leading zeros. CBP validates each entry number against its internal database, so even minor formatting differences will cause a rejection.

Common formatting errors include: entry numbers truncated by Excel (which removes leading zeros from numeric-looking strings), extra whitespace characters, non-ASCII characters introduced by copy-paste operations, and duplicate entry numbers. Tariffi's generation process avoids all of these by working directly from the parsed ES-003 data without any intermediate spreadsheet handling.

The file size limit for CAPE Phase 1 submissions is generous but not unlimited. For very large filings (tens of thousands of entries), your broker may need to split the submission into batches. Tariffi pre-splits files at the appropriate threshold and provides your broker with sequenced batch files ready for upload.

Common CAPE errors and how to fix them

Understanding the most frequent CAPE filing errors saves time and accelerates your refund. Based on data from the early months of CAPE Phase 1 operations, the following error categories account for the vast majority of rejections.

Drawback conflicts are the single most common rejection reason. If an entry has an associated drawback claim (where duties were refunded because the goods were subsequently exported), CBP will reject a CAPE refund claim on the same entry to prevent double recovery. Before filing, verify that none of your qualifying entries have pending or completed drawback claims. Tariffi's pre-filing audit engine cross-references drawback records to flag these conflicts.

Entry-not-found errors occur when the entry number in the CAPE CSV does not match any record in CBP's database. This is almost always a formatting issue: a leading zero was stripped, a digit was transposed, or the entry number was modified by a spreadsheet application. The fix is to ensure entry numbers are treated as text strings, never as numbers, throughout the entire preparation process.

Unable-to-calculate-duty rejections happen when CBP's internal systems cannot determine the correct refund amount for an entry. This typically affects entries with complex duty structures involving both ad valorem and specific-rate components, or entries where a post-summary correction is still being processed. Your broker may need to provide supplemental documentation to CBP to resolve these cases.

PSC-incomplete rejections affect entries where a Post-Summary Correction has been filed but not yet finalized by CBP. Until the correction is complete and the entry is re-liquidated, CBP cannot process a refund claim against it. These entries should be held and refiled after the PSC is resolved. Tariffi tracks PSC status and flags these entries during the analysis stage.

The submission process: from data to declaration

The CAPE submission process involves coordination between three parties: the importer (who provides the data and authorization), Tariffi (which analyzes the data and prepares the filing package), and the licensed customs broker (who reviews and submits the declaration to CBP).

After you upload your ES-003 and sign the authorization documents, Tariffi generates the complete filing package. This package includes: the CAPE-format CSV containing qualifying entry numbers, a summary report listing each entry with its tariff authority, rate differential, and estimated refund amount, and any compliance flags that the broker should review. The package is delivered to your broker through a secure portal.

Your broker reviews the package against their professional obligations under 19 CFR Part 111. This review is not a formality. The broker verifies that the entries are correctly classified, that the tariff authority cited is accurate, and that no disqualifying conditions exist. If the broker identifies issues, they work with Tariffi to resolve them before filing.

Once the broker approves the package, they log into the ACE portal, navigate to the CAPE section, and upload the CSV file. CBP provides an immediate acknowledgment of receipt. Processing begins on a rolling basis, with most declarations receiving initial validation results within two to four weeks of submission.

What happens after your CAPE declaration is submitted

After your broker submits the CAPE declaration, CBP's automated validation system processes each entry number in the file. The system checks that the entry exists in CBP's records, that the tariff program cited is applicable, that the entry has not already been refunded, and that no disqualifying conditions (such as drawback conflicts) exist.

Entries that pass validation are approved for refund. CBP calculates the refund amount based on the rate differential between what was paid and the revised rate. The refund is queued for ACH disbursement to the importer of record. As of February 2026, all CBP refunds are delivered via ACH; paper checks have been eliminated.

Entries that fail validation are returned with a rejection code. Your broker receives the rejection notification through ACE. Tariffi monitors for rejections and, where the issue is correctable (such as a formatting error or a resolved PSC), prepares a corrected submission for your broker to refile. Not all rejections are correctable; drawback conflicts, for example, are a permanent disqualification for the specific entry.

You can track the overall status of your declaration through your broker or by checking the ACE portal directly (if you have portal access). Tariffi also provides status updates as we receive them from the broker. The timeline from submission to refund receipt is typically 30 to 60 days for approved entries.

CAPE pass rates and rejection analysis

CAPE Phase 1 has demonstrated a pass rate exceeding 97 percent in its initial months of operation. This high rate reflects the system's design: Phase 1 handles the simplest category of claims where the overpayment is straightforward to verify from existing CBP records.

The approximately 2 to 3 percent rejection rate is concentrated in a few categories. Drawback conflicts account for the largest share, followed by PSC-incomplete entries, entries where CBP cannot calculate the duty (complex rate structures), and formatting errors in the submitted CSV. All of these are identifiable before filing with proper pre-submission screening.

Tariffi's pre-filing audit engine is specifically designed to minimize the rejection rate. By flagging drawback conflicts, PSC-incomplete entries, and other disqualifying conditions before the filing reaches your broker, the effective pass rate for Tariffi-prepared declarations is expected to exceed the overall CAPE average. Entries that would be rejected are excluded from the filing and tracked separately for potential future recovery.

For brokers filing on behalf of multiple clients, tracking the aggregate pass rate across all filings provides a useful quality metric. A pass rate significantly below the CAPE average suggests a systemic issue in the data preparation process. Tariffi provides per-filing and aggregate analytics to help brokers monitor their filing quality.

How Tariffi prepares your CAPE declaration

Tariffi's role in the CAPE process is strictly data preparation. Under CBP Ruling HQ H326926, technology platforms may prepare customs data as long as a licensed broker performs the actual filing and exercises professional judgment. Tariffi operates within this framework.

The preparation process begins when you upload your ES-003 file. Tariffi's parser extracts all entry data and normalizes it into a consistent format. The analysis engine then evaluates each entry against the applicable IEEPA and Section 301 proclamation schedules, checking HTS codes, entry dates, origin countries, and liquidation status to determine eligibility.

For eligible entries, the engine calculates the estimated refund amount based on the rate differential. It also runs a compliance check to flag entries with drawback conflicts, PSC-incomplete status, or other conditions that could cause a rejection. The result is a clean, validated set of entry numbers ready for CAPE submission.

The CAPE-format CSV, the summary report, and the compliance flag report are packaged together and delivered to your broker. Tariffi does not submit anything to CBP. The broker receives the package, reviews it, and makes the independent decision to file. This separation of data preparation and filing is fundamental to the compliance architecture and is required by 19 U.S.C. section 1641.

The broker's role in CAPE filings

The licensed customs broker is the Filer of Record for every CAPE declaration. This is not a formality; the broker has substantive legal obligations under 19 CFR Part 111 and professional liability for the accuracy of the filing.

When the broker receives Tariffi's prepared filing package, they are expected to review the entry list for accuracy, verify that the tariff authority cited for each entry is correct, confirm that no disqualifying conditions exist, and exercise independent professional judgment on the filing decision. CBP Ruling HQ H350722 specifically addresses this: 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.

The broker submits the declaration through their own ACE portal access using their credentials. The filing appears in CBP's system under the broker's license number. If CBP has questions or requires additional information, they contact the broker directly.

For brokers, CAPE filings represent both a revenue opportunity and a professional obligation. The flat per-filing filer integration fee compensates the broker for their review and filing services. The fee is structured as a data-service payment, not a revenue share, in compliance with 19 CFR section 111.36.

Getting started: your first CAPE filing with Tariffi

The fastest path from zero to a filed CAPE declaration follows a simple sequence. First, export your ES-003 file from the ACE portal following the steps outlined above. If you are unsure about the date range, select the widest range available to capture all potentially eligible entries.

Second, upload your ES-003 at tariffi.io/intake/start. Tariffi parses the file in seconds and presents your estimated refund amount, broken down by tariff authority and entry count. This estimate is free and requires no commitment. You can review the numbers with your finance or compliance team before proceeding.

Third, if you choose to proceed, complete the signing package. This includes the Contingency Fee Agreement (disclosing the fee percentage), the LPOA (authorizing your broker to file), and the Three-Party Indemnification Agreement (clarifying each party's responsibilities). All signing is electronic.

Fourth, your broker receives the prepared filing package, reviews it, and submits the CAPE declaration through ACE. You will receive status updates as CBP processes your claim. The entire process from upload to broker submission typically takes less than a week. CBP processing adds 30 to 60 days, and the ACH deposit follows within a few business days after that.

If you have questions at any stage, Tariffi's support team is available to help. You can also use the HTS lookup tool at tariffi.io/hts to check whether specific product codes are covered by IEEPA or Section 301 tariffs, or the refund calculator at tariffi.io/calculator to model different scenarios before uploading your data.