Do I need commercial invoices and proof of payment to claim an IEEPA refund, or just my entry numbers?

For a CAPE Declaration you submit only the entry numbers, not invoices or proof of payment. But you must be able to produce them: CBP may review a CAPE claim before issuing the refund, and the 19 CFR 163 recordkeeping duty applies. For a protest, invoices and proof of payment are part of the submitted package. An importer with $610,000 across 700 entries keeps an invoice and an ACH or broker duty statement per entry, submitted for protests, retained for CAPE.

What is the ES-003 report and why is it the one document every IEEPA refund starts with?

The ES-003 (Entry Summary Line Tariff Details) is a standard ACE report listing every tariff line of every entry, including the Chapter 99 lines (9903.01 and 9903.02) where IEEPA duty sits. Every route depends on it because it identifies which entries carried IEEPA duty, how much, and their liquidation status, deciding CAPE versus protest. Pull one ES-003, filter for 9903.01 and 9903.02, and you get the refund figure and route split. GingerControl's IEEPA Refund Recovery works from that export, not from ACE.

If CBP says no supporting documents are required for a CAPE Declaration, why does everyone tell me to gather paperwork?

Because 'nothing submitted' is not 'nothing needed.' CBP requires no attachments beyond the entry-number list at CAPE submission, but you still need source documents to build the list correctly (the ES-003, to confirm which lines are IEEPA versus Section 301 or 232), and you must retain the full entry record under 19 CFR 163. A team that submits a clean CSV but cannot later substantiate it has met the submission rule and failed the retention rule. They are separate obligations.

How do I pull my ES-003 report from ACE to build my CAPE entry list?

In the ACE Portal, switch to your Importer of Record account, go to Reports, then the Entry Summary folder, and open ES-003 (Entry Summary Line Tariff Details). Set the date range on the entry-summary date field, add the Liquidation Status and Liquidation Date columns, run it, and export to Excel. Then filter the HTS column for 9903.01 and 9903.02 to isolate IEEPA lines. The step-by-step version, with folder path and empty-pull failures, is in the ES-003 walkthrough linked below.

What documents does an IEEPA protest need that a CAPE Declaration does not, given I have entries liquidated four months ago?

A protest under 19 CFR 174 needs a full package CAPE never asks for: CBP Form 19 (in quadruplicate), the entry summary (7501), the commercial invoice, proof of payment, and a written legal basis citing Learning Resources v. Trump and the CIT refund order. Entries liquidated about four months ago are past the 80-day CAPE window but usually inside the 180-day protest window, so protest is often the route. Which entry goes CAPE, protest, or PSC is a separate decision.

Is CBP Form 7501 (the entry summary) required for an IEEPA refund, and what does it prove?

The 7501 is not uploaded for a CAPE Declaration, but it is part of a protest package and a retained record for every route. It proves three things: who the Importer of Record is (your standing to claim), which Chapter 99 lines carried IEEPA duty, and the duty amounts. For a $610,000 book it is the backbone of the audit file even on CAPE entries, because if CBP reviews, it is the first document they reconcile against your list.

I paid the IEEPA duties but I am not the importer of record on some DDP courier entries; what documents let me still recover?

CBP refunds the party with standing, the Importer of Record, not necessarily whoever paid the duty commercially. On DDP courier shipments the courier or seller is often the IOR, so you generally need a power of attorney or a written assignment from the IOR, or you recover through the IOR. Confirm the IOR on the 7501 before you assume you can claim. Whether you were the IOR on DDP entries is its own question; resolve standing first.

How long do I have to keep my IEEPA refund records, and under what rule?

Five years from the date of entry, under 19 CFR 163.4 and 19 U.S.C. 1509. The refund does not reset, extend, or shorten that clock; it runs from the original entry date regardless of when you file or receive it. The records to produce are the (a)(1)(A) list: entry summaries, invoices, packing lists, bills of lading, certificates of origin, purchase orders, contracts, and payment records. A 2025 entry that generates a 2026 refund still ages out on its 2025 date.

If CBP reviews or audits my IEEPA refund claim, what documents will they ask me to produce?

The (a)(1)(A) list under 19 CFR 163: the entry summary (7501), commercial invoices, proof of duty payment, packing lists, bills of lading or air waybills, certificates of origin, and the underlying purchase orders and contracts. CBP may review a CAPE claim before issuing the refund, so 'submitted nothing' does not mean 'produce nothing later.' For a 700-entry claim, a defensible file is one folder per entry, retained 5 years, so a coordinator can pull any entry on demand.

IEEPA Refund Documents Required: The Complete Checklist for CAPE, PSC, and Protest Claims

The documents required for an IEEPA tariff refund, by route: CAPE submits an entry-number list only, a protest needs a full package, and you retain records 5 years.

Chen Cui· Co-Founder of GingerControl· July 17, 2026

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

A CAPE Declaration submits a list of entry numbers and nothing else, but you still gather the ES-003 to build it, a protest needs a full evidence package, and you must retain the entire entry record for 5 years.

Your CFO said "get our money back," CBP's CAPE portal is open, and you are at the part nobody explains cleanly: what paperwork do you actually need? This checklist gives the exact documents per route, the ones you gather but never upload, and the ones you keep in case CBP asks.

An IEEPA refund has two document tiers that people conflate. Tier one is what you submit: a CAPE Declaration submits a CSV of entry numbers only, no attachments, up to 9,999 entries; a protest submits a full package (CBP Form 19, entry summary, commercial invoice, proof of payment, written legal basis). Tier two is what you retain and must produce on demand: the complete entry record under 19 CFR 163, kept for five years from the date of entry. Behind every route you first pull the ES-003 report to identify your IEEPA lines and liquidation status.

Primary sources: U.S. Customs and Border Protection, IEEPA Duty Refunds and 19 CFR Part 163, Recordkeeping. Both are linked throughout and listed in full under References.

This is a documents checklist, not a deadline guide and not a route picker. For when to file, the protest clock math lives in the 180-day liquidation deadline guide. If you are not sure whether an entry goes through CAPE, PSC, or protest, decide the channel first in the CAPE vs protest vs PSC decision guide. For the full end-to-end process, the hub is the IEEPA tariff refund guide.

What documents do I need to file an IEEPA tariff refund claim?

The documents you need depend on the route, so stop thinking of it as one list. There are two document tiers, and confusing them is the most common and expensive mistake on these claims. Tier 1 is what you submit, and it varies wildly by route. Tier 2 is what you retain and produce on demand, the same for every route: the full entry record under 19 CFR 163, kept for five years.

That gap is the whole point of this post, because CAPE is quietly misleading. When CBP says "no supporting documentation is required at submission beyond the list of entry numbers," a reasonable person hears "no documents needed." It means "do not upload anything," a submission rule, not a recordkeeping rule. And nothing here is automatic: CBP's guidance is explicit that every refund, including on unliquidated entries, starts with an affirmatively filed CAPE Declaration; CBP reliquidates and pays only after your declaration is accepted. Here is the per-route matrix:

Route	When it applies	Submitted at filing	Must retain and produce on demand
CAPE Declaration	Unliquidated entries and entries liquidated within 80 days, filed in ACE	CSV of entry numbers only, up to 9,999, no attachments	ES-003, entry summaries, invoices, proof of payment (for your validation and any CBP review)
Post Summary Correction (PSC)	Non-IEEPA corrections on unliquidated entries, filed before the CAPE Declaration (not an IEEPA refund route itself)	Corrected entry data through ACE	Entry summary, invoices, supporting entry documents
Protest (CBP Form 19)	Liquidated entries within 180 days of liquidation	Full package: Form 19 (quadruplicate), 7501, commercial invoice, proof of payment, written legal basis	Same package, retained 5 years
CIT complaint	Entries past the 180-day administrative window	Court complaint, coordinate outside counsel	Full entry record

Route sources: CBP CSMS bulletins for CAPE; 19 CFR 174 and 19 U.S.C. 1514 plus CBP Form 19 for protests; 19 CFR 163 for retention. Route selection itself is a separate decision, covered in the CAPE vs protest vs PSC decision guide. For an importer carrying $610,000 across roughly 700 entries, both the top and bottom of this table apply at once.

What documents do I gather before I file, on any route?

Before any route, you gather five things that let you build a correct claim and substantiate it later, the same whether an entry ends up in CAPE or protest.

The ES-003 report (Entry Summary Line Tariff Details) from ACE. The one document every IEEPA refund starts with: it lists every tariff line, carries the liquidation status that decides your route, and is where you isolate the 9903.01 and 9903.02 lines. Pull it under the Importer of Record account with the Liquidation Status and Date columns added.
CBP Form 7501 (the entry summary), per entry. Identifies the IOR (your standing) and the duty lines. Not uploaded for CAPE, but the backbone of any protest and every retained file.
Commercial invoice, per entry, establishing the goods and value behind the duty.
Proof of duty payment: an ACH statement, broker duty statement, or Periodic Monthly Statement showing the IEEPA duty was paid.
Liquidation status and date, per entry. More a field than a document, but it decides whether an entry is CAPE-eligible, protest-eligible, or already time-barred.

The full ES-003 procedure and the four ways it silently comes back short is a guide of its own: if you have not pulled it, start with how to pull the ES-003 report in ACE, and if you lack ACE access, request ACE Portal access first. That clean entry list becomes the CSV you upload; building and submitting the CAPE Declaration in ACE turns these documents into a filed claim.

One filtering caution: only 9903.01 and 9903.02 are refundable IEEPA duty. Section 301, 232, and 122 also live in Chapter 99 under different subheadings, so a broad 9903 filter inflates the expected refund and can flag the claim. The which HTS codes carry IEEPA duties guide is the full taxonomy.

Why does CAPE ask for so few documents when a protest asks for so many?

CAPE asks for almost nothing because it is a bulk reliquidation mechanism, not an adjudication, while a protest asks for a full package because it is a legal challenge to a liquidation. This is the CAPE simplicity trap. With CAPE there is no argument to make, because the Supreme Court already decided IEEPA tariffs were unlawful and the CIT ordered CBP to give the money back; CBP just validates your entry numbers and reliquidates.

A protest is the opposite. Under 19 CFR 174, a protest on CBP Form 19 (filed in quadruplicate) contests a liquidation, and CBP will not act on a bare assertion, so the package carries the evidence CAPE never asks for: the entry summary (7501), the commercial invoice, proof of duty payment, and a written legal basis citing Learning Resources, Inc. v. Trump (decided February 20, 2026) and the CIT refund order of March 4, 2026, establishing that the IEEPA duty was unlawfully collected.

That gap is why you must know your route before assembling anything: a protest package for a CAPE-eligible entry wastes days, and a bare CAPE list for an ineligible entry gets rejected. Decide the channel in the CAPE vs protest vs PSC decision guide.

What standing documents do I need if I am not the importer of record?

If you paid the IEEPA duty commercially but you are not the Importer of Record, you need a power of attorney or a written assignment from the IOR, because CBP refunds the party with standing, and standing follows the IOR number, not the invoice. This is the standing-proof chain. Start with the 7501, which names the IOR: if it is you, the chain is short; if it is not, the classic case being a DDP courier shipment where the carrier or seller was the IOR, you file through them or with their POA or assignment.

Whether you were the IOR is its own question; work it out in am I the importer of record for an IEEPA refund and, for the DDP case, DDP shipments, couriers, and IOR. If a broker or authorized filer will submit on your behalf, the power of attorney for an IEEPA refund filer covers the authorization documents.

What documents do I keep, and for how long?

You keep the full entry record for five years from the date of entry, under 19 CFR 163.4 and 19 U.S.C. 1509, and the refund does not change that clock. This is the retention-clock frame: it runs from the date of entry, not the refund, so a 2025 entry that generates a 2026 refund ages out on the 2025 anniversary.

What you must be able to produce is the (a)(1)(A) list, the records CBP designated under 19 U.S.C. 1509(a)(1)(A) and published as an appendix to 19 CFR Part 163, meaning any information required by law or regulation for the entry of the merchandise:

Entry summaries (7501)
Commercial invoices
Packing lists
Bills of lading and air waybills
Certificates of origin and country-of-origin marking documentation
Purchase orders and contracts
Payment records, including the proof of duty payment

This matters because CAPE may be subject to a CBP compliance review before the refund is issued: you submitted nothing but an entry list, so if CBP pulls the claim, the tier-two records are what stand behind it. The practical build is one folder per entry containing its (a)(1)(A) documents, retained five years, so a coordinator can pull any entry on demand.

What are the most common document mistakes on IEEPA refunds?

The failures I see are rarely about a missing invoice; they are about misreading which document rule applies, or which entry is eligible. These six undo good claims.

Treating "no documents required" as "no records needed." The 19 CFR 163 retention duty is unchanged by CAPE.
Including non-IEEPA lines in the refund total. Only 9903.01 and 9903.02 are IEEPA; filtering on all of 9903 sweeps in Section 301, 232, and 122 lines.
Waiting for CAPE on a liquidated entry, then finding it was excluded. Entries flagged for reconciliation, on drawback claims, under open protests, not filed in ACE, or subject to AD/CVD with pending Commerce liquidation instructions were excluded from CAPE Phase 1, and the 180-day protest window can close while you wait. The deadline math is in the 180-day deadline guide.
Filing a bare CAPE list on an ineligible entry and getting it rejected. The pre-flight validation that catches this is in how to file the CAPE Declaration correctly. For FTZ Type 06 admissions that trip HTS-mismatch rejections, see FTZ Type 06 CAPE rejection and HTS mismatch.
A non-IOR trying to claim without a power of attorney or assignment. On DDP courier entries the courier is often the IOR. Resolve standing before assembling.
Malformed entry numbers in the CSV. CAPE validation rejects incomplete or wrongly formatted entry numbers. Error codes and fixes are in CAPE Declaration rejected.

Where the refund process stands right now

As of mid-July 2026 the document rules above are stable, but the eligibility landscape is still moving, which changes an entry's route more than its paperwork.

CAPE has moved past its April 20, 2026 launch. Phase 2 opened June 29, 2026, extending CAPE to reconciliation-flagged entries where the Type 09 reconciliation entry has not yet been filed and the entry is unliquidated or within 80 days of liquidation. Phase 3, targeted for late July 2026, is expected to cover finally-liquidated entries, but the government has taken the position that those refunds go only to importers who filed lawsuits at the Court of International Trade.

On the litigation side, the government filed notices of appeal of the CIT refund order with the Federal Circuit in early June 2026, arguing the nationwide orders are impermissible universal injunctions. That appeal is expected to take months but has not halted refunds: the CIT partially stayed its orders while CBP built CAPE, yet refunds are actively processing, with roughly $23 billion approved and transmitted to Treasury as of the June 9, 2026 CIT hearing. For where entries outside the current phases land, see CAPE Phase 2 scope, timeline, and eligibility.

The takeaway: because eligibility shifts phase by phase, read your ES-003 liquidation status per entry and confirm the route before you build a package for an entry that just changed lanes.

Turning the document list into a filed claim

Assembling these documents by hand is doable, and for a few hundred entries you should just do it: the ES-003 pull is free, the (a)(1)(A) list is documents you already have, and one folder per entry is an afternoon.

The manual method strains at volume and route-mixing. When 700 entries mix CAPE candidates, protest entries, DDP entries where you may not be the IOR, and FTZ Type 06 or reconciliation-flagged edge cases, the hard part is not any single document. It is sorting every entry into its route by liquidation status and knowing which are days from a protest deadline. Do that by hand and the error bars widen where a six-figure refund lives.

That sorting is where GingerControl's IEEPA Refund Recovery service fits. Working from the ES-003 export you provide, it filters the Chapter 99 lines, sums the IEEPA duty as a fact from your file rather than a rate estimate, and buckets each entry into CAPE, protest, or time-barred by the 180-day clock, flagging entries within 30 days of a protest deadline, with an IEEPA refund calculator built on those same ES-003 duty amounts.

To set expectations honestly: GingerControl is builder-not-broker, human-in-the-loop software and advisory. It prepares and files the refund package and can coordinate outside counsel for a CIT complaint, but it is not a licensed customs broker, it is not the Importer of Record, it does not file your underlying customs entries, it does not pull from ACE for you, it is not legal counsel, and it does not guarantee a refund amount or CBP acceptance. You still gather the documents and hold the records; the service route-sorts the stack.

FAQ

What is in an IEEPA protest package? CBP Form 19 (in quadruplicate), the entry summary (7501), the commercial invoice, proof of duty payment, and a written legal basis citing the Supreme Court decision and the CIT refund order, filed under 19 CFR 174 within 180 days of liquidation.

Which HTS lines count as IEEPA duty on my documents? Only 9903.01 (fentanyl and trafficking family) and 9903.02 (reciprocal family). Section 301, 232, and 122 duties sit under other 9903 subheadings and are not IEEPA and not refundable through this process.

IEEPA Tariff Refund Guide: ACE, CAPE, and Deadlines, the hub for the whole refund process.
How to Pull the ES-003 Report in ACE, the first document on every route.
CAPE vs Protest vs PSC: Choosing Your Refund Channel, decide the route first.
The 180-Day Liquidation Deadline for IEEPA Protests and CAPE, the timing math.
How to File the CAPE Declaration Correctly, the pre-flight validation.
Am I the Importer of Record for an IEEPA Refund?, resolve standing first.

References

CBP CSMS #68340863, "UPDATE, Consolidated Administration and Processing of Entries (CAPE) for IEEPA Refunds, April 20, 2026 Deployment," issued April 13, 2026. content.govdelivery.com
U.S. Customs and Border Protection, "International Emergency Economic Powers Act (IEEPA) Duty Refunds," accessed July 2026. cbp.gov
eCFR, 19 CFR Part 163, "Recordkeeping," including the (a)(1)(A) list appendix, accessed July 2026. ecfr.gov
19 CFR 163.4, "Record retention period." law.cornell.edu
eCFR, 19 CFR Part 174, "Protests," accessed July 2026. ecfr.gov
Supreme Court of the United States, Learning Resources, Inc. v. Trump, No. 24-1287, decided February 20, 2026. supremecourt.gov
Holland & Knight, "IEEPA Tariff Refund Update: Government Appeals CIT Refund Order and the Road Ahead for Importers," June 2026. hklaw.com
White & Williams, "IEEPA Tariff Refunds: CBP Launches CAPE Process," 2026. whiteandwilliams.com

Written by

Chen Cui

Co-Founder of GingerControl

Building scalable AI and automated workflows for trade compliance teams.

LinkedIn Profile

Frequently Asked Questions

What documents do I need to file an IEEPA tariff refund claim?: It depends on the route. A CAPE Declaration submits a CSV of entry numbers only, no attachments, up to 9,999 per declaration. A protest needs a full package: CBP Form 19, the entry summary (7501), commercial invoice, proof of payment, and a written legal basis. Every route also gathers the ES-003 to identify IEEPA lines and retains the record for 5 years. An importer with $610,000 across 700 entries files most through CAPE and a remainder through protest, so both sets apply.
Do I need commercial invoices and proof of payment to claim an IEEPA refund, or just my entry numbers?: For a CAPE Declaration you submit only the entry numbers, not invoices or proof of payment. But you must be able to produce them: CBP may review a CAPE claim before issuing the refund, and the 19 CFR 163 recordkeeping duty applies. For a protest, invoices and proof of payment are part of the submitted package. An importer with $610,000 across 700 entries keeps an invoice and an ACH or broker duty statement per entry, submitted for protests, retained for CAPE.
What is the ES-003 report and why is it the one document every IEEPA refund starts with?: The ES-003 (Entry Summary Line Tariff Details) is a standard ACE report listing every tariff line of every entry, including the Chapter 99 lines (9903.01 and 9903.02) where IEEPA duty sits. Every route depends on it because it identifies which entries carried IEEPA duty, how much, and their liquidation status, deciding CAPE versus protest. Pull one ES-003, filter for 9903.01 and 9903.02, and you get the refund figure and route split. GingerControl's IEEPA Refund Recovery works from that export, not from ACE.
If CBP says no supporting documents are required for a CAPE Declaration, why does everyone tell me to gather paperwork?: Because 'nothing submitted' is not 'nothing needed.' CBP requires no attachments beyond the entry-number list at CAPE submission, but you still need source documents to build the list correctly (the ES-003, to confirm which lines are IEEPA versus Section 301 or 232), and you must retain the full entry record under 19 CFR 163. A team that submits a clean CSV but cannot later substantiate it has met the submission rule and failed the retention rule. They are separate obligations.
How do I pull my ES-003 report from ACE to build my CAPE entry list?: In the ACE Portal, switch to your Importer of Record account, go to Reports, then the Entry Summary folder, and open ES-003 (Entry Summary Line Tariff Details). Set the date range on the entry-summary date field, add the Liquidation Status and Liquidation Date columns, run it, and export to Excel. Then filter the HTS column for 9903.01 and 9903.02 to isolate IEEPA lines. The step-by-step version, with folder path and empty-pull failures, is in the ES-003 walkthrough linked below.
What documents does an IEEPA protest need that a CAPE Declaration does not, given I have entries liquidated four months ago?: A protest under 19 CFR 174 needs a full package CAPE never asks for: CBP Form 19 (in quadruplicate), the entry summary (7501), the commercial invoice, proof of payment, and a written legal basis citing Learning Resources v. Trump and the CIT refund order. Entries liquidated about four months ago are past the 80-day CAPE window but usually inside the 180-day protest window, so protest is often the route. Which entry goes CAPE, protest, or PSC is a separate decision.
Is CBP Form 7501 (the entry summary) required for an IEEPA refund, and what does it prove?: The 7501 is not uploaded for a CAPE Declaration, but it is part of a protest package and a retained record for every route. It proves three things: who the Importer of Record is (your standing to claim), which Chapter 99 lines carried IEEPA duty, and the duty amounts. For a $610,000 book it is the backbone of the audit file even on CAPE entries, because if CBP reviews, it is the first document they reconcile against your list.
I paid the IEEPA duties but I am not the importer of record on some DDP courier entries; what documents let me still recover?: CBP refunds the party with standing, the Importer of Record, not necessarily whoever paid the duty commercially. On DDP courier shipments the courier or seller is often the IOR, so you generally need a power of attorney or a written assignment from the IOR, or you recover through the IOR. Confirm the IOR on the 7501 before you assume you can claim. Whether you were the IOR on DDP entries is its own question; resolve standing first.
What extra documentation do FTZ Type 06 or reconciliation-flagged entries need for an IEEPA refund?: Reconciliation-flagged entries were excluded from CAPE Phase 1 and became eligible under Phase 2 on June 29, 2026, but only where the Type 09 reconciliation entry has not yet been filed and the entry is unliquidated or within 80 days of liquidation; otherwise they route to protest or a later phase. FTZ Type 06 admissions can trip HTS-mismatch rejections. You retain the same 19 CFR 163 record set, but eligibility, not documents, is the gating issue.
How long do I have to keep my IEEPA refund records, and under what rule?: Five years from the date of entry, under 19 CFR 163.4 and 19 U.S.C. 1509. The refund does not reset, extend, or shorten that clock; it runs from the original entry date regardless of when you file or receive it. The records to produce are the (a)(1)(A) list: entry summaries, invoices, packing lists, bills of lading, certificates of origin, purchase orders, contracts, and payment records. A 2025 entry that generates a 2026 refund still ages out on its 2025 date.
If CBP reviews or audits my IEEPA refund claim, what documents will they ask me to produce?: The (a)(1)(A) list under 19 CFR 163: the entry summary (7501), commercial invoices, proof of duty payment, packing lists, bills of lading or air waybills, certificates of origin, and the underlying purchase orders and contracts. CBP may review a CAPE claim before issuing the refund, so 'submitted nothing' does not mean 'produce nothing later.' For a 700-entry claim, a defensible file is one folder per entry, retained 5 years, so a coordinator can pull any entry on demand.

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