How Do You File a CAPE Declaration Correctly? Pre-Flight Checklist

How do I file a CAPE Declaration correctly so it is not rejected?

You file a CAPE Declaration correctly by running a pre-flight checklist before you upload: validate ACE account setup (ACH refund profile, POA, filer authorization), filter the ES-003 to only 9903.01 and 9903.02 lines with non-zero duty inside the Phase 1 liquidation window, verify FTZ Type 06 HTS sequencing, and confirm the CSV header and entry-number format. Doing these checks in order eliminates roughly 90% of the rejection patterns ACE returns.

What is the single most common preventable CAPE rejection?

The most common preventable rejection is a missing or inactive ACH Refund Authorization on the importer sub-account, which lets the declaration accept but routes the refund to a paper check instead of direct deposit. The second is including entries whose 9903.01 or 9903.02 line shows $0 or FREE, which adds noise that triggers entry-level errors and slows the per-entry validation pass.

TL;DR

The mechanics of submitting a CAPE Declaration through ACE are simple. The reason first-time filers get rejected is that the checks that would have caught the issue never happened before the upload. This article is the pre-flight checklist I run, in order, before clicking submit: account hygiene, ES-003 filtering, Phase 1 scope verification, HTS sequence validation for FTZ entries, filer authorization, CSV format, math sanity-check, and post-upload monitoring. It is the proactive companion to the reactive rejection-code troubleshooting guide and assumes you have already read the general ACE CAPE submission walkthrough. GingerControl built the two free calculators on the IEEPA refund toolkit page precisely because pre-flight validation is the highest-leverage step in the entire refund process.

Last updated: May 2026

Why a pre-flight checklist matters more than the upload itself

CAPE Phase 1 launched at 8 a.m. EST on April 20, 2026 per CSMS # 68315804, following the Supreme Court's February 20, 2026 ruling in Learning Resources, Inc. v. Trump and Judge Eaton's March 4, 2026 CIT order mandating nationwide refunds. Since launch, importers and brokers have submitted tens of thousands of declarations, and the rejection patterns are now well-mapped. The reactive troubleshooting work (parsing Validation Result Files, routing rejected entries to Post Summary Correction, 19 USC 1514 protest, or CIT) is real and unavoidable for declarations that already bounced. What I want to address here is the upstream work: how to make sure the first declaration goes through cleanly.

The shift to a pre-flight mindset matters because Post Summary Correction is no longer available as a clean-up tool for IEEPA refunds. Since April 20, 2026, PSC is blocked for IEEPA refund corrections, and CAPE is the exclusive administrative mechanism. Phase 1 covers unliquidated entries and entries within 80 days of liquidation. Everything past that window forces a protest under 19 USC 1514 within 180 days, or a CIT complaint. A rejected CAPE upload eats clock that you cannot get back.

Pre-flight validation is the only step in the IEEPA refund process where you can recover 100% of the recoverable amount without burning a deadline. After upload, every fix consumes time that the protest clock is already counting.

Step 1: ACE account hygiene before you touch a CSV

This is where preventable rejections originate. The CSV format is the easy part. The account state is what trips first-time filers.

ACH Refund Authorization on the importer sub-account

The ACH profile you use to pay duties is not the ACH profile CBP uses to send you a refund. They are configured separately in the ACE Portal. As EisnerAmper's IEEPA refund analysis puts it: "the bank account you use to pay CBP import duties is not the account CBP uses to send you a refund. They are separate setups."

The checklist item: log into the ACE Portal, open the importer sub-account, navigate to the ACH Refund Authorization tab, and confirm an active bank profile is on file. If the tab is blank, the declaration may validate but the refund will route to a paper check mailed to the address on file. CBP takes 5 to 10 business days to activate a new ACH Refund profile, so this is the first item to fix on any new engagement.

CF-4811 Notify Party designation (broker/agent receiving the refund)

If the IOR wants the refund to flow to a broker or agent rather than directly to the importer, the CF-4811 Notify Party designation needs to be on file. Without it, CBP sends the refund to the IOR's address regardless of who filed the CAPE. This is a frequent source of post-refund disputes between importers and the service providers who did the recovery work.

Active POA covering CAPE filings

A broker, service provider, or law firm filing CAPE on behalf of an importer needs a current power of attorney that actually covers CAPE submissions. Older POA language drafted for routine entry filing may or may not reach refund recovery filings depending on how it was scoped. I walk through the POA-for-CAPE specifics in the filer authorization article, and the practical move is to confirm POA scope before you start building the CSV.

Importer sub-account linked to a single EIN

If the same EIN sits under two ACE sub-accounts (parent and subsidiary both set up, or two filer codes that both opened Importer sub-accounts), CAPE cannot cleanly route the refund. The fix is to consolidate to one active sub-account per EIN, deactivate the duplicate, and update the IOR-to-sub-account mapping before filing.

Step 2: ES-003 validation before you build the CSV

The ES-003 Entry Summary Line Tariff Details report is the source of truth for which entries paid IEEPA duty. The default export does not give you everything you need.

ES-003 column	Default included?	Why it matters for CAPE
Entry Number	Yes	Goes into the CAPE CSV
HTS line / Chapter 99 prefix	Yes	Filter to 9903.01 and 9903.02 only
Line-level duty amount	Yes	Filter out $0 / FREE lines
Liquidation Status	No, add it	Determines CAPE Phase 1 scope
Liquidation Date	No, add it	Calculates 80-day cliff per entry
Entry Date	Yes	Confirms IEEPA window (Feb 4 2025 to early Feb 2026)

The checklist:

Add Liquidation Status and Liquidation Date columns to the ES-003 export before you do anything else. They are not in the default column set, and you need both to decide Phase 1 eligibility per entry.
Filter to 9903.01 and 9903.02 lines only. Section 301 (9903.88), Section 232 (9903.80/.81/.85), and Section 122 (9903.03) are not refundable through CAPE. Including them in the CSV adds entries that will be rejected at the entry-level validation pass.
Exclude lines where the IEEPA duty is $0 or FREE. If a duty-free provision applied (de minimis, exclusion, FTA preference) or the rate was coded FREE, there is nothing to refund and the entry will bounce.
Verify the entry date window. IEEPA Chapter 99 codes took effect February 4, 2025, and the IEEPA framework was struck down in early February 2026. Entries outside that window paid duty under a different authority and are not in CAPE scope.

The ES-003 walkthrough covers the column-by-column mechanics. The pre-flight version is: run ES-003 with Liquidation Status and Liquidation Date added, filter to 9903.01/.02, drop $0/FREE, and confirm the date window.

Step 3: Phase 1 scope verification per entry

This is where I see the most well-intentioned mistakes. Importers pull the ES-003, see a long list of IEEPA-paying entries, and dump them all into a CAPE CSV. Phase 1 is narrower than that.

Entry liquidation status	CAPE Phase 1 eligible?	Alternative route
Unliquidated	Yes	None needed
Liquidated within 80 days	Yes	None needed
Liquidated 81 to 180 days ago	No	19 USC 1514 protest
Liquidated more than 180 days ago	No	CIT complaint

Bottom line: Phase 1 is a two-bucket eligibility test (unliquidated, or liquidated within 80 days). Every other entry maps to a different administrative route with its own deadline clock. Putting a 90-day-liquidated entry on a CAPE CSV does not extend its protest window, it just wastes the upload and lets the 180-day Form 19 deadline run while you re-route.

The CAPE-eligible entries breakdown covers the eligibility matrix in detail, and the IEEPA refund timeline overlays the protest and CIT deadlines so you can sequence multiple routes for a single book of entries.

Step 4: HTS sequence validation for FTZ Type 06 entries

If your declaration includes Foreign-Trade Zone Type 06 (FTZ withdrawal) entries, this step is non-negotiable. Sequence mismatch is the single most common rejection pattern on FTZ entries, and I have seen the same Type 06 entry produce "UNABLE TO CALCULATE DUTY" one day and "HTS RELATIONSHIP/SEQUENCE MISMATCH" the next when the CAPE module tries to validate it.

The FTZ-specific issue is that privileged foreign status and non-privileged foreign status entries have different HTS line sequencing requirements, and the underlying e214 admission status drives which sequence applies. If the entry summary's HTS lines do not match the admission status pattern CBP expects, the CAPE validation engine cannot resolve the duty calculation and the entry bounces.

The pre-flight check: pull each FTZ Type 06 entry summary and compare the HTS line ordering against the e214 admission. If the sequence does not match the privilege status, do not include the entry on the CAPE CSV. Per CBP's guidance and the pattern documented across the trade bar, the right move for FTZ sequence-mismatch cases is to email IEEPARefunds@cbp.dhs.gov with the entry numbers, the FTZ Type 06 designation, and the expected error text, rather than re-submitting. The FTZ Type 06 sequence-mismatch walkthrough has the email template and the technical detail on which sequence applies to which admission status.

Step 5: Filer code and authorization

CAPE requires that the first three characters of each entry number match the filer code of the ACE account submitting the declaration. This rule is what trips brokers who acquired client relationships from another broker, or service providers filing on behalf of importers whose original broker has gone dark.

The pre-flight check has three parts:

Filer code match. Take the first three characters of every entry number in your CSV. Compare to the filer code of the ACE account that will submit the declaration. Any mismatch is a guaranteed entry-level rejection.
IOR-direct workaround. If the filer codes do not match, the cleanest fix is for the IOR to file CAPE directly from its own ACE account. The IOR account is matched on EIN rather than filer code, which sidesteps the rule. This requires the IOR to have an ACE Portal account, which most do not by default.
POA scope confirmation. If a broker or service provider is filing, the POA must cover CAPE submissions specifically. Older POA language drafted before April 2026 may or may not reach refund recovery filings, depending on how it was scoped.

Step 6: CSV format validation

The format is unforgiving. Get it exactly right or the file-level validation fails and rejects the entire declaration before entry-level checks even run.

CSV element	Requirement
Cell A1 header	Exactly "Entry Number" (no quotes, no extra spaces)
Column count	One column only, no extras
Entry number format	11 characters: 3-char filer code + 7-digit serial + 1-digit check digit
Rows per entry	One entry per row, no concatenation
Maximum entries per file	9,999 per declaration
Duplicates	Not allowed within the same declaration
File extension	.csv (Comma delimited)
Encoding	Standard CSV, no BOM, no special characters

The most common file-level failures I see: a stray space in cell A1 ("Entry Number " with trailing space), an extra column from a spreadsheet template that was not cleaned out, or a 10-character entry number where the check digit was dropped during export. All three look identical to the human eye, all three kill the upload.

Step 7: Sanity-check the math before upload

Before submitting, compare the expected refund total against your finance team's expectation. If the two numbers diverge by more than roughly 5%, something is wrong on one side.

The math per entry, in plain English: the refund amount is the duty paid on the 9903.01 or 9903.02 line, not the total duty paid on the entry. Section 301 duty on a 9903.88 line, Section 232 duty on a 9903.80/.81/.85 line, Section 122 duty on a 9903.03 line, and base MFN duty on the underlying classification line are all owed and are not refundable.

CBP adds statutory interest on top of the refund amount. Per CBP's IEEPA Duty Refunds Fact Sheet, interest accrues from the date of original payment. The Holland & Knight April 2026 alert estimates that statutory interest pushes the total refundable amount to roughly 82% of total IEEPA duties collected, around $127 billion of the $166 billion collected. For your own declaration, the refund total should match your finance team's expectation (which is typically just the line-item duty figure) plus a few percent of interest. If the gap is wider than that, recheck the filter step.

Step 8: Post-upload monitoring

The pre-flight work ends at submit. The post-upload check still has a cadence.

24 to 48 hours after upload, pull the Validation Result File from the File Upload Status column of the CAPE tab in the ACE Portal. The file lists per-entry accept/reject status and the error code for any rejection.
If the file was accepted at file level and entry level, the entries move into the refund queue. CBP's commitment is a refund within 60 to 90 days following acceptance, per the CBP IEEPA Duty Refunds Fact Sheet. The payment shows as REV-603 in the ACH detail.
If specific entries were rejected at the entry level, fix the underlying issue per the CAPE rejection error-code guide and re-file only the affected entries on a new declaration.
If the file was rejected at the file level, the entire declaration was bounced. Fix the format or authorization issue and re-upload the complete CSV.

GingerControl is AI global trade compliance infrastructure that helps importers, exporters, and customs brokers classify products, simulate tariff costs, and track policy changes. For IEEPA refund recovery specifically, the upstream pre-flight work is what protects the per-entry refund amount from getting stuck in the rejection-and-route cycle.

Pre-flight checklist at a glance

For the importer or broker filing their first CAPE Declaration, here is the checklist in one block.

Step	Check	Common failure if skipped
1	ACH Refund Authorization active on IOR sub-account	Refund routes to paper check
1	CF-4811 Notify Party designation if broker receiving refund	Refund routes to wrong party
1	Active POA covering CAPE filings	File-level authorization rejection
1	Single Importer sub-account per EIN	Refund routing conflict
2	ES-003 export with Liquidation Status and Date columns	Cannot verify Phase 1 scope
2	Filter to 9903.01 and 9903.02 lines only	Section 301/232/122 entries bounce
2	Exclude $0 / FREE IEEPA lines	Entry-level rejection
2	Confirm Feb 4 2025 to early Feb 2026 entry date window	Out-of-window rejection
3	Phase 1 scope verification per entry (unliquidated or within 80 days)	Out-of-scope rejection, deadline burn
4	FTZ Type 06 HTS sequence vs e214 admission status	HTS sequence mismatch error
5	Filer code matches submitting ACE account	Filer authorization rejection
5	POA scope confirmed for CAPE filings	File-level authorization rejection
6	CSV: "Entry Number" exact header, 11-char entries, no duplicates	File-level format rejection
6	Maximum 9,999 entries per declaration	File size rejection
7	Refund total matches finance expectation within ~5%	Wrong entries on the file
8	Pull Validation Result File 24 to 48 hours after upload	Missed rejection windows

FAQ

How long should the pre-flight checklist take before my first CAPE Declaration? For a clean importer with ACE access already configured, the pre-flight work takes a few hours: an hour on ACH Refund and POA verification, an hour on ES-003 filtering, and an hour on Phase 1 scope and CSV preparation. For an importer building ACE access from scratch, add 5 to 10 business days for the ACH Refund profile to activate. GingerControl's IEEPA refund toolkit includes a free ES-003 drop-in calculator that does the filtering, bucketing, and refund-amount math in the browser, which is the fastest way to size the opportunity before filing.

Can I skip the ES-003 filter step and just upload all my entries from the IEEPA window? You can, but the validation pass will reject every entry that does not have a 9903.01 or 9903.02 line with non-zero duty, plus every entry outside the Phase 1 liquidation scope. The rejected entries do not get a free pass to re-file. Each one consumes a slot on the Validation Result File and slows the per-entry routing decision after the fact. GingerControl's ES-003 drop-in calculator pre-filters the export so only genuinely CAPE-eligible entries land on the CSV.

What is the difference between this pre-flight checklist and the general CAPE submission guide? The general ACE CAPE submission guide walks through the end-to-end filing process from ES-003 to refund disbursement. This pre-flight checklist focuses narrowly on the validation work you do before you upload, so the declaration clears ACE on the first try. They are companion articles. GingerControl files the full IEEPA recovery package for importers who want both the pre-flight work and the post-rejection routing handled.

Is Post Summary Correction still an option if my CAPE Declaration is rejected for a non-IEEPA reason? PSC is blocked for IEEPA refund corrections specifically since April 20, 2026. PSC remains available for non-IEEPA entry corrections (classification, valuation, country of origin) where the entry is unliquidated or pre-liquidation, subject to the standard PSC time limits. GingerControl maps each rejected entry to the correct administrative route, including PSC where it is still legal for non-IEEPA corrections, Form 19 protest for past-80-day liquidated entries within 180 days, or CIT coordination for older entries.

How do I know if my POA covers CAPE filings? Read the POA's scope clause. Older POAs drafted before April 2026 generally cover routine entry filing, post-summary correction, and protest, but may or may not explicitly authorize CAPE Declarations. The conservative move is to execute a CAPE-specific addendum or a new POA that names CAPE submissions explicitly. GingerControl's POA for IEEPA filer authorization article has model language that has been accepted by ACE for CAPE filings.

Does GingerControl file the CAPE Declaration, or do I file it myself? Both options are supported. The free ES-003 drop-in calculator and the quiz-style estimator are the no-cost first step for importers who want to size the opportunity and self-file. GingerControl also files the full IEEPA refund recovery package under POA for importers who want the work handled, including CAPE filing, Form 19 protest for past-80-day entries, and CIT coordination for older entries. The documents-required checklist covers the records GingerControl needs for the full-service engagement.

What happens to interest accrual while I am running the pre-flight checklist? Interest accrues from the date of original payment regardless of when you file. The pre-flight work itself does not slow interest accrual. What does slow interest accrual is a rejected declaration that has to be diagnosed, routed, and re-filed, because each round of rejection-and-re-file pushes the actual acceptance date out. GingerControl tracks per-entry interest accrual inside the recovery workbook so the finance team can reconcile the refund payment against the expected duty-plus-interest amount.

Size your recoverable amount before you file

Before you build a CAPE CSV, get an honest read on what is actually recoverable across your entries. The IEEPA refund toolkit on the GingerControl site has two free calculators that produce the number in minutes, no upload required.

The ES-003 drop-in calculator is for importers who already have their ACE export. Drag the file into the browser, and it parses locally (nothing leaves your machine), classifies each line by Chapter 99 prefix (9903.01 and 9903.02 as IEEPA refundable, 9903.88 as Section 301, 9903.80/.81/.85 as Section 232, 9903.03 as Section 122), buckets entries by liquidation status (CAPE Phase 1 eligible, Form 19 protestable within 180 days, time-barred), and returns total IEEPA duties paid plus the estimated recoverable amount. It is the fastest way to confirm which entries belong on the CAPE CSV and which need a different route.

The quiz-style estimator is for importers who do not have their ES-003 pulled yet. A handful of questions about your import volume, IEEPA exposure, and entry mix produces a directional refund estimate. Use it to decide whether the full ES-003 pull is worth the operational lift this week.

Both calculators are the no-cost first step before filing. If the recoverable amount justifies handing off the work, GingerControl files the full IEEPA refund recovery package under POA: CAPE Declarations for Phase 1 entries, PSC where still legal for non-IEEPA corrections, Form 19 protest for entries past the 80-day Phase 1 window but within 180 days of liquidation, and CIT coordination for older entries.

Run the ES-003 drop-in calculator or the quiz-style estimator

Talk to our team about full-service IEEPA refund recovery, including CAPE filing, protest preparation, and CIT coordination.

References

[REF 1] U.S. Customs and Border Protection, CSMS # 68315804, CAPE for IEEPA Refunds Introduction Data cited: April 20, 2026 CAPE Phase 1 launch, ACE Portal channel, prerequisite list Source: CSMS # 68315804 Published: April 2026

[REF 2] U.S. Customs and Border Protection, CAPE Phase 1 Trade Information Notice Data cited: Phase 1 scope (unliquidated + 80 days post-liquidation), file-level vs entry-level validation, PSC block for IEEPA refunds Source: CAPE Phase 1 Trade Information Notice Published: April 2026

[REF 3] U.S. Customs and Border Protection, IEEPA Duty Refunds Fact Sheet Data cited: 60-90 day refund timeline, ACH-only refund payment, statutory interest accrual Source: IEEPA Duty Refunds Fact Sheet Published: April 2026

[REF 4] U.S. Customs and Border Protection, ACE Portal CAPE Declarations and Error Definitions Data cited: File-level vs entry-level validation, error message taxonomy, Validation Result File mechanics Source: CBP CAPE Declarations and Error Definitions Published: May 2026

[REF 5] U.S. Supreme Court, Learning Resources, Inc. v. Trump Data cited: February 20, 2026 ruling invalidating IEEPA tariffs Source: Supreme Court opinion 24-1287 Published: February 20, 2026

[REF 6] Holland & Knight, CAPE Has Arrived Data cited: 82% / $127 billion refundable estimate including statutory interest, Phase 1 mechanics Source: Holland & Knight CAPE guide Published: April 2026

[REF 7] Thompson Hine SmartTrade, CBP Confirms April 20, 2026 Launch of CAPE Phase 1 Data cited: CAPE Phase 1 launch confirmation, scope to unliquidated and within-80-day entries Source: CBP Confirms April 20 2026 Launch of CAPE Phase 1 Published: April 2026

[REF 8] EisnerAmper, IEEPA Tariff Refunds CAPE System Now Live Data cited: ACH Refund Authorization tab separate from ACH Debit, banking setup as gating issue Source: EisnerAmper IEEPA Tariff Refunds CAPE System Live Published: April 2026

[REF 9] White and Williams, IEEPA Tariff Refunds CBP Launches CAPE Process Data cited: CSV upload mechanics, 9,999-entry-per-declaration limit, Chapter 99 line removal mechanics Source: White and Williams IEEPA Tariff Refunds CAPE Process Published: 2026

[REF 10] 19 U.S.C. 1514, Protest provisions Data cited: 180-day protest deadline from liquidation Source: 19 USC 1514