Direct Answer
A CAPE Declaration is a CSV file submitted by a U.S. importer of record or their licensed customs broker through CBP's ACE Secure Data Portal to claim IEEPA tariff refunds. It lists entry numbers for which refunds are sought. ACE validates the file, removes IEEPA HTS Chapter 99 codes, reliquidates entries, and triggers Treasury ACH payment of duties plus interest.
The Supreme Court’s February 20, 2026 ruling in Learning Resources v. Trump opened $166 billion in IEEPA refunds for 330,000 importers of record across 53 million entry summaries. As of June 29, 2026, $71.06 billion has been certified and sent to Treasury through CBP’s CAPE system (Phase 1, Phase 2, and Phase 3), with statutory interest accruing at approximately $650 million per month under 19 U.S.C. § 1505.
CAPE Declaration — What It Is and How It Works
What is a CAPE Declaration?
Step 1
What a CAPE Declaration Contains
A CAPE Declaration is a single-column CSV file with 'Entry Number' in the first row and your entry numbers in subsequent rows. It is limited to 9,999 entries per Declaration — importers with larger portfolios submit multiple Declarations. No supporting documentation is required at submission beyond the entry number list.
Step 2
Who Can Submit a CAPE Declaration
Only two parties can submit a CAPE Declaration: (1) the Importer of Record named on CBP Form 7501, filing through their own ACE account, or (2) the licensed customs broker who filed the original entry summaries, filing under a valid Power of Attorney. A freight forwarder, trade consultant, or third-party advisor who is not the broker of record cannot submit directly.
Step 3
How ACE Processes a CAPE Declaration
Upon upload in the CAPE tab of ACE, two sequential validation series run. File-level validation checks submitter identity, file format, and the presence of entry numbers — a file-level failure rejects the entire Declaration. Entry-level validation checks each entry individually for a valid ACE record, at least one dutiable IEEPA Chapter 99 HTS code, and no duplicate entry numbers — entry-level failures reject individual entries while valid entries continue to process.
Step 4
What Happens After Validation
Entries that pass both validations have their IEEPA HTS Chapter 99 codes removed. ACE recalculates duties owed without the IEEPA codes and reliquidates the entry. The duty difference — the IEEPA amount plus statutory interest under 19 U.S.C. § 1505 — is consolidated by IOR and transmitted to Treasury for ACH disbursement.
Step 5
CAPE Declaration Limitations
CAPE Declarations cannot be amended once accepted in ACE. Additional entries require a new Declaration. Each Declaration is capped at 9,999 entries. Warehouse entries (Types 21/22) are no longer accepted after July 7, 2026 per CSMS #69127837. Phase 2 Declarations must not include entries with a filed Type 09 reconciliation entry — sequence the CAPE Declaration before the Type 09.
Common Questions
Frequently Asked Questions
What file format is the CAPE Declaration?
The CAPE Declaration is a CSV (comma-separated values) file using the template available in the CAPE tab of the ACE Secure Data Portal. Column A contains 'Entry Number' in Row 1 and entry numbers in subsequent rows.
What is the entry limit per CAPE Declaration?
Each CAPE Declaration is limited to 9,999 entries. Importers with larger portfolios submit multiple Declarations — there is no limit on the number of Declarations an IOR or broker can submit.
Can a CAPE Declaration be amended after submission?
No. Once a CAPE Declaration is accepted in ACE, it cannot be amended. Additional entries must be submitted in a new Declaration. Rejected entries can be corrected and resubmitted in a new Declaration.
What is the most common reason a CAPE Declaration is rejected?
The most common reasons are: no qualifying IEEPA Chapter 99 HTS code on the entry, duplicate entry numbers, ineligible entry types (Types 21/22 after July 7), entries with a filed Type 09 for Phase 2 filings, and incorrect ACH enrollment. Industry-wide discrepancy rates are approximately 30% per Gaia Dynamics analysis.
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Note: The CAPE Declaration template is available only in the ACE Secure Data Portal. The Tariff Bureau prepares, validates, and delivers the CAPE Declaration CSV to your licensed customs broker — we do not submit in ACE on your behalf.
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Informational only. Not legal, tax, or financial advice. The Tariff Bureau LLC is not a law firm, is not a licensed customs broker, and is not affiliated with CBP or any U.S. government agency. The IEEPA statute of limitations accrual date remains legally unsettled. Consult qualified trade counsel for your specific situation.