How to File a CAPE Declaration in ACE for IEEPA Refunds (Step-by-Step)

File a CAPE Declaration in the ACE Portal: build a CSV of entry numbers, certify, upload in the CAPE tab, and read the result. Refunds land by ACH in 60-90 days.

Chen Cui

Chen Cui· Co-Founder of GingerControl

Connect with me on LinkedIn! I want to help you :)
Reviewed by: Michael Weick, LCB / CCS

Customs compliance manager with 42 years of experience (ex Subaru of America, Merck, and Motorola).

TL;DR

To file a CAPE Declaration in ACE, upload a CSV of entry numbers only in the CAPE tab, certify, and CBP recalculates the refund and pays it by ACH in 60-90 days.

Your broker just handed you an ACE login and said "you can file the CAPE Declaration yourself now." You open the portal, see a CAPE tab, and freeze, because there is a seven-figure refund on the line and nobody wants to be the person who bounced a $2M claim by uploading the wrong file. The mechanics are genuinely simple once you know them, but the interface tells you nothing and CBP's own guidance is scattered across CSMS bulletins. I built the tool that sizes these claims, and when we mapped the rejections our users hit, almost all of them trace to the same handful of file-format mistakes. Here is the exact submission, click by click, plus how to read whether it worked.

To file a CAPE Declaration in ACE, open the CAPE tab in the ACE Secure Data Portal, download the CAPE Upload Template, enter one 11-character entry number per row (entry numbers only, no HTS codes or duty amounts), save it as a CSV, tick the certification box, and click Upload File. One Declaration holds up to 9,999 entries. CBP recalculates the refund from its own records, assigns a CAPE claim number, and pays valid refunds by ACH within 60-90 days of acceptance. Only the Importer of Record or its filing broker can submit.

Primary sources: CBP's IEEPA duty refunds guidance and CBP's CAPE declarations and error definitions guidance. Both are linked throughout and listed in full under References.

What is a CAPE Declaration and how do you submit one in ACE?

A CAPE Declaration is a CSV file of entry numbers you upload in the CAPE tab of the ACE Portal to request a refund of IEEPA duties, submitted by downloading CBP's template, entering your entry numbers, certifying, and clicking Upload File. CAPE stands for Consolidated Administration and Processing of Entries, the channel CBP built inside ACE after the Supreme Court struck down IEEPA tariffs on February 20, 2026. CBP launched CAPE Phase 1 on April 20, 2026, at 8:00 AM EDT, and it is now the exclusive administrative channel for these refunds. A Post Summary Correction does not trigger an IEEPA refund; CBP prohibits using a PSC for this purpose.

This is the how-to-submit guide, not the pre-flight checklist. If you want to validate the entry list before you upload, read How Do You File a CAPE Declaration Correctly? first. And if you do not have ACE Portal access yet, that is a different first step covered in How to Request ACE Portal Access to File an IEEPA Tariff Refund. This post starts once you are already logged in and staring at the CAPE tab.

What do you need before you can file a CAPE Declaration?

You need two things before the CAPE tab is usable: an active ACE Secure Data Portal account for the Importer of Record (or a broker with portal access filing on the IOR's behalf), and ACH refund enrollment on file with CBP. Only the IOR or the filing customs broker may submit a Declaration. The ACH piece is the one people forget: CBP issues these refunds by ACH only, so if your company is not enrolled in ACH refunds, the Declaration can clear and the money still has nowhere to land. If you are the sole compliance manager at a mid-market importer, confirm ACH enrollment with your finance team this week, before you touch the CAPE tab, because enrolling after the fact only adds delay to a refund you have already earned.

A quick reality check on who you are. If you are the IOR's in-house compliance manager with ACE access, you can do everything below yourself. If you are a junior broker filing for several IOR clients, the same steps apply per client, and the certification you tick attests you are legally authorized to file for that IOR. GingerControl is neither of those; it is software that prepares the claim, not the party that submits it.

Where is the CAPE tab in the ACE Portal?

The CAPE tab is a dedicated tab in the web-based ACE Secure Data Portal, added in the April 20, 2026 Phase 1 deployment. You reach it after logging into the ACE Portal with an account tied to the IOR whose entries you are refunding. If you do not see a CAPE tab at all, that is almost always a permissions problem on the account rather than a missing feature, and it is the access issue the ACE-access guide walks through. Once the tab is visible, everything you need lives on that one screen: the template download link, the certification checkbox, and the Upload File button.

What goes in the CAPE CSV file?

The CAPE CSV file holds entry numbers and nothing else, one 11-character entry number per row, under a header cell that reads Entry Number in A1. You do not put HTS codes, duty amounts, dates, or invoice values in the file. CBP pulls all of that from its own records and recalculates the refund itself; the CSV is purely a list of which entries to look at.

Here is the exact build:

  1. Download the CAPE Upload Template. Click the CAPE Upload Template link in the CAPE tab. ACE downloads an Excel spreadsheet with a single column headed Entry Number in cell A1 and every row below it blank. CBP's own error-definitions document describes this template.
  2. Do not touch the A1 header. If you delete or rename the Entry Number header, the file is rejected at format check. This is one of the two or three most common self-inflicted bounces.
  3. Paste your entry numbers, one per row. Each is 11 characters, alphanumeric; dashes are optional. Add nothing else. No extra columns, no notes, no duty totals.
  4. Save as CSV. Use CSV (Comma delimited) (*.csv), not .xlsx. Saving the template back out as an Excel workbook is a frequent format-check rejection.

A practical note on scale. One Declaration holds up to 9,999 entries, so if finance handed you a list of ~600 candidate entries, that is a single file. If you are past 9,999, split into multiple Declarations; there is no penalty for filing several, and each gets its own claim number.

The file is just a list, not a claim form

The single most common misread of CAPE is treating the CSV like a duty-refund worksheet. It is not. You are handing CBP a list of entry numbers and saying "recompute these without the IEEPA duty." Every HTS code, every dollar figure, every date comes from CBP's records, not your spreadsheet. If your file has more than one column, delete the extra columns before you upload.

How do you certify and upload the CAPE Declaration?

You certify and upload by ticking the certification checkbox in the CAPE tab, which enables the Upload File button, then selecting your CSV. The certification is an attestation that you are legally authorized to make the filing for that IOR, and the Upload File button stays greyed out until the box is checked, so if you cannot click Upload, look for the checkbox you have not ticked yet. After you upload, a progress bar runs and, on success, a confirmation message appears on screen. That confirmation is your first signal the file passed the format layer; it is not yet the final word on whether every entry qualifies.

For a compliance manager filing 600 entries in one shot, this whole step is under a minute. The anxiety is real but the interaction is small: check the box, pick the file, watch the bar.

What happens after you upload, and how does CBP calculate the refund?

After you upload, ACE runs two validation series and then, for the entries that pass, strips the IEEPA duty and reliquidates. The first series is file validations, which confirm the entry numbers are complete and properly formatted, that you are authorized to submit, and that the file is intact. The second is entry-specific validations, which check each entry individually. Per CBP's April 20 deployment bulletin, an entry has to have a Chapter 99 IEEPA HTS declaration present, an acceptable liquidation status, no open or suspended protest, no reconciliation flag, no drawback association, an eligible entry type (types 08, 09, and 47 are excluded), and it must be within 80 days of its liquidation date, with goods value properly reported on the Chapter 1-97 lines.

If an entry fails an entry-specific validation, CBP removes that one entry from the Declaration and keeps processing the rest. For valid entries, ACE removes the dutiable IEEPA Chapter 99 code, recalculates the duty without it, and liquidates or reliquidates the entry; already-liquidated entries reliquidate the next business day. You never calculate the refund yourself, which is exactly why the CSV only needs entry numbers.

How do you know if your CAPE Declaration was accepted or rejected?

You know it was accepted when the Declaration returns a confirmation and a unique CAPE claim number, and you know an entry was rejected when ACE itemizes it and tells you why. The claim number is your tracking handle for the whole batch. Crucially, acceptance and rejection are per entry, not all-or-nothing: if you filed 600 entries and 40 fail entry-specific validation, the other 560 continue processing and only the 40 drop out, listed with their failure reasons. You do not refile the whole batch, you fix the 40 and refile just those.

To monitor status after acceptance, CBP published a set of ACE reports specifically for tracking CAPE refund claims. Use the CAPE claim number with those reports rather than emailing your broker for updates. When an upload does bounce, do not guess at the cause; the error text is specific. The CAPE Error Decoder translates every message, and CAPE Declaration Rejected? Error Codes and How to Fix covers the re-file mechanics. Two rejections have their own dedicated fixes worth knowing about up front: FTZ Type 06 HTS-sequence mismatches and reconciliation-flagged entries. This guide deliberately does not re-teach those; the linked posts do.

When do you actually get paid?

You generally get paid within 60-90 days after CBP accepts the Declaration, by ACH, and since acceptance itself takes roughly 10 days, plan on about 70-100 days from upload to deposit. CBP's guidance frames the 60-90 day window as 45 days for its own review plus Treasury processing time. The refund is ACH-only, which is why ACH enrollment is a prerequisite and not an afterthought. For a CFO who wants the money "this quarter," the honest answer is that a clean 600-entry Declaration uploaded today realistically pays out late in the following quarter, not this one, and the single biggest accelerant is submitting a file that clears validation on the first pass instead of bouncing and restarting the clock.

The scale of what is moving is real, not theoretical. By June 29, 2026, CBP had authorized about $104 billion in IEEPA refunds and paid out roughly $71 billion including interest, against a total IEEPA universe of around $166 billion. Under Phase 1 alone, CBP had accepted roughly $90 billion in claims and transmitted about $23 billion to Treasury for disbursement. The channel works and the people who filed clean, organized claims early are the ones getting paid.

What if your entries do not qualify for Phase 1?

If your entries do not qualify for Phase 1, the path depends on why, and for some categories CAPE is genuinely not the right channel. Let me be two-sided here, because the honest answer matters more than a clean walkthrough. Three situations fall outside the standard submission above:

One more thing worth stating plainly: the underlying refund right is not fully settled in court. The government appealed the CIT's nationwide refund order to the Federal Circuit in early June 2026, and that appeal is still pending as of July 2026. CBP keeps processing CAPE refunds regardless, so CAPE is the operational channel to use now, but do not assume the legal question is closed while you file.

How do you file a CAPE Declaration at scale without burning the claim?

You file at scale by getting the entry list right before you ever open the CAPE tab, because at 600 or 6,000 entries the failure mode is not the upload, it is a messy source list that bounces piecemeal and drags out the clock. The manual method above is complete and free, and for most single-Declaration filings you do not need anything else. Where it gets hard is the pre-work: pulling your ES-003 import history, isolating the entries that actually carry a Chapter 99 IEEPA code, checking each entry's liquidation status against the 80-day window, and separating the Phase 1 entries from the ones that belong in a protest or Phase 2. Do that wrong and you either miss eligible refunds or feed CBP entries that were always going to bounce.

That pre-work is where GingerControl fits, and I want to be precise about the boundary. GingerControl is trade-compliance software and consulting, not a licensed customs broker: it does not file your underlying customs entries or act as your Importer of Record. What our IEEPA Refund Recovery service does is file the full refund package: it estimates the recoverable amount from your ES-003 duty history, flags each entry's liquidation status and protest deadline, produces the clean entry list, and handles the submission so the claim clears validation the first time. It estimates the recoverable amount; it does not guarantee a refund figure or CBP acceptance, because no one honestly can. And if you want a heads-up the next time CBP changes the rules mid-stream, the way it did with the July 7 warehouse cutoff, Tariff Briefings tracks CBP and Federal Register changes for you.

Try GingerControl for your IEEPA refund

If you are sitting on a stack of IEEPA entries and are not sure which ones qualify or how much you can recover, GingerControl's IEEPA Refund Recovery service sizes the claim from your ES-003 history and files the full refund package, so the CAPE Declaration goes in clean the first time. See how IEEPA Refund Recovery works.

Bottom line

Filing a CAPE Declaration is not the hard part; getting the entry list clean is. The submission itself is a four-step build (download the template, paste entry numbers only, save as CSV, certify and upload) and CBP does the math. The real risks are the ones that quietly cost you money: an .xlsx file that bounces at format check, a renamed A1 header, an entry that finally liquidated 90 days ago and quietly aged out of Phase 1, or a company that files a perfect Declaration and then waits because it was never enrolled in ACH. Get those right, file a clean file, and a 600-entry, seven-figure claim moves through the same 60-90 day pipeline as a small one.

References

Chen Cui

Written by

Chen Cui

Co-Founder of GingerControl

Building scalable AI and automated workflows for trade compliance teams.

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Frequently Asked Questions

How do I file a CAPE declaration in the ACE Portal, step by step?
Open the CAPE tab in the ACE Secure Data Portal, download the CAPE Upload Template, enter one entry number per row, save it as CSV, tick the certification box, and click Upload File. If you are the compliance manager handling roughly 600 IEEPA entries, that is one Declaration and about ten minutes of work once the CSV is clean. GingerControl's IEEPA Refund Recovery service can build and size that entry list, and files the full refund package for you if you would rather not run the upload yourself.
What exactly goes in the CAPE CSV file, just entry numbers or the HTS and duty too?
Only the 11-character entry numbers, one per row, under the Entry Number header in cell A1. You do not enter HTS codes, duty amounts, or dates; CBP recalculates everything from its own records. A $60M importer with 600 entries pastes 600 entry numbers and nothing else. Adding extra columns is one of the most common reasons a first upload bounces at format check.
How many entries can one CAPE declaration hold, and how do I handle 600 or more entries?
One CAPE Declaration holds up to 9,999 entries, so 600 entries fit in a single file. If you are a large importer or a broker filing for several clients past 9,999 entries, split the list across multiple Declarations. There is no penalty for filing several; each gets its own CAPE claim number for tracking.
Can I file a CAPE declaration on an entry that has already liquidated?
Yes, if the entry liquidated within the past 80 days; past that it is finally liquidated and Phase 1 rejects it. For a compliance manager racing the clock on older 2025 entries, the 80-day-since-liquidation date is the deadline that actually matters. Finally-liquidated entries route to a 19 U.S.C. 1514 protest or CAPE Phase 3, which is limited to importers who sued at the Court of International Trade. See our protest-versus-CAPE guide for that fork.
How long after I submit a CAPE declaration will I actually get the refund?
CBP generally issues valid IEEPA refunds within 60-90 days after it accepts the Declaration, and acceptance itself takes roughly 10 days, so plan on 70-100 days from upload to money. Refunds are paid by ACH only, so if your company is not enrolled in ACH refunds the money has nowhere to land. A $2M claim across 600 entries follows the same clock as a small one.
Can I file CAPE on entries flagged for reconciliation or on warehouse entries?
Reconciliation-flagged entries were rejected in Phase 1 and now route through CAPE Phase 2, which opened June 29, 2026. Warehouse entries (Types 21 and 22) stopped being accepted on a CAPE Declaration on July 7, 2026; you file the warehouse withdrawal (Types 31, 32, 34, 38) instead. If your exposure sits in either bucket, the sibling posts linked below cover the exact workflow so this guide stays focused on the standard submission.
How do I know whether my CAPE declaration was accepted or is in trouble?
An accepted Declaration returns a confirmation message and a unique CAPE claim number; a rejected one tells you which entries failed and why. If you filed 600 entries and 40 come back rejected, the other 560 still process, they are not held hostage by the failures. Track status with the CAPE claim number and the ACE monitoring reports CBP published for exactly this purpose.
My CAPE declaration got rejected, do I have to refile everything?
No. Valid entries keep processing and ACE removes only the individual entries that failed entry-specific validation, itemized so you can see the reason. You fix the rejected entries and refile just those in a new Declaration. A compliance-of-one does not re-upload all 600 entries because 40 bounced; you re-upload the 40. Our error-decoder and rejection posts translate each specific error message.
Does the importer file the CAPE declaration, or does the customs broker have to?
Either the Importer of Record with ACE Portal access or the filing customs broker can submit the CAPE Declaration; there is no rule that a broker must do it. Many mid-market importers whose broker handed them an ACE login file it themselves. GingerControl is not a broker, but its IEEPA Refund Recovery service prepares, sizes, and files the full refund package, or hands you the clean file if you prefer to upload it yourself.
Can GingerControl file my CAPE declaration for me?
Yes. GingerControl's IEEPA Refund Recovery service files the full refund package for you: it estimates the recoverable amount from your ES-003 history, flags each entry's liquidation status and deadline, and handles the submission end to end. If you prefer to run the upload yourself, it hands you a validation-clean file instead. GingerControl is not a licensed customs broker and does not act as your Importer of Record, and it guarantees no refund amount or CBP acceptance.

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