Question 1

What is a Pre-CAPE audit and why do I need one?

Accepted Answer

A Pre-CAPE audit scans your ES-003 file and checks every entry against CBP's published rejection rules before you submit your CAPE Declaration. This matters because once CAPE accepts your declaration, PSC corrections are permanently blocked for those entries under CSMS #68397097 (Error Code 864). If a bad entry slips through and gets accepted, you lose the refund for that entry with no recourse. The audit catches fixable issues while you still can.

Question 2

Can I permanently lose part of my IEEPA refund by filing wrong?

Accepted Answer

Yes. The most direct path: you submit a CAPE Declaration that includes an entry with an unfixable error. CAPE accepts it. CBP later flags the entry for correction. But PSC is now blocked by Error Code 864. The refund for that entry is gone. A second path: missing the 180-day Form 19 protest window for liquidated entries. Past that date, the refund is barred permanently under 19 U.S.C. §1514.

Question 3

What is Error Code 864?

Accepted Answer

Error Code 864 — 'PSC NOT ALLOWED – REFUND REQUESTED' — is issued by CBP when you try to file a Post-Summary Correction on an entry that's already included in an accepted CAPE Declaration. PSC is blocked permanently for those entries. There is no workaround. The only protection is auditing your entries before you submit. Source: CSMS #68397097.

Question 4

What does 'Refund permanently barred' mean in my audit results?

Accepted Answer

It means the entry was liquidated more than 180 days ago. The protest window under 19 U.S.C. §1514 has closed. CAPE Phase 1 will not accept it, and the deadline to file a Form 19 protest has already passed. No refund path remains for this entry. If you see this on entries with significant duty amounts, consult a licensed customs attorney about alternative remedies.

Question 5

What does 'File Form 19 protest — not CAPE eligible' mean?

Accepted Answer

It means the entry was liquidated between 81 and 180 days ago — outside the 80-day CAPE Phase 1 window but still within the protest window. CAPE will reject it, but you can still get a refund by filing a Form 19 protest directly with CBP within 180 days of the liquidation date. The audit shows your specific deadline for each affected entry. Source: 19 U.S.C. §1514.

Question 6

Why is my 9903.01.63 entry flagged for review?

Accepted Answer

HTS code 9903.01.63 carried a 125% reciprocal tariff rate — but only for entries between April 10 and May 13, 2025. Outside that window, the applicable rate is 10%. If your entry date falls outside that range, the 125% rate should not apply, which means either the HTS classification or the duty calculation may be off. Verify with your broker before submitting to avoid triggering an overpayment flag. Source: EO 14257 (as amended April 9, 2025).

Question 7

Why is my 9903.01.24 entry flagged?

Accepted Answer

Code 9903.01.24 changed rates on November 10, 2025 — from 20% to 10% — per EO 14357. If your entry date falls within 14 days of that cutoff, the audit flags it for manual verification. A one-day difference in entry date can mean a 10-point rate difference. Submitting with the wrong rate won't always cause an immediate CAPE reject, but it creates a discrepancy that CBP may flag later, at which point PSC is no longer available. Source: EO 14357, CSMS #66749380.

Question 8

What entries are excluded from CAPE Phase 1 entirely?

Accepted Answer

CAPE Phase 1 does not accept: entries liquidated more than 80 days before your submission date; entries with open or suspended protests; entries with drawback claims (Phase 2 only); reconciliation entries (type 09); entry types 08, 23, and 47; and AD/CVD entries. Submitting an excluded entry won't result in a penalty, but it wastes your submission slot. Source: CBP CAPE FAQ, April 2026.

Question 9

What should I do if the audit flags a Yellow entry?

Accepted Answer

Yellow means the audit detected a potential issue that requires your review — it does not mean you should skip the entry. For rate-related flags (9903.01.24 or 9903.01.63): verify the entry date and HTS classification with your broker before submitting. For Form 19 flags: don't submit through CAPE. File a protest directly with CBP before the deadline shown. For any Yellow entry with significant duty, consider a quick check against your original Form 7501 before filing.

Question 10

Does the audit guarantee CAPE will accept my entries?

Accepted Answer

No. The audit checks for issues visible in your ES-003 file: liquidation dates, HTS codes, rate cutoffs, and entry types. It cannot detect open protests, drawback claims, reconciliation flags, account mismatches, or debt offsets — none of those appear in ES-003. The disclaimer on results is accurate: this is a pre-submission check, not a guarantee. CBP is the final authority. What the audit does is eliminate the most common fixable errors before they become permanent.

Question 11

How long does it take to receive a refund after filing CAPE?

Accepted Answer

CBP's published estimate is 60–90 days from acceptance. Early reports from Phase 1 filers suggest some entries are being reliquidated faster than the official estimate, though the ACH payment itself may follow later.

Question 12

What do I do with the CAPE CSV after downloading it?

Accepted Answer

Log in to ACE Portal → navigate to the CAPE tab → click Upload Declaration → select the file → Submit. CBP validates each entry and returns a status. Accepted entries show a Claim Status of 'CAPE Accepted' and will appear as 'Re-liquidated' in your ACE reports once processed. Refunds are issued via ACH to the bank account you have on file with CBP. Entries that are extended, suspended, or under review receive refunds at the time of liquidation rather than immediately. Source: CBP.gov, April 2026.

Question 13

Is my ES-003 file safe to upload?

Accepted Answer

Yes. Parsing runs entirely in your browser — your file is never uploaded to our servers. Nothing is transmitted until you pay, and even then only the count of eligible entries and your estimated refund amount go to our payment processor. The CAPE CSV is generated locally and downloaded directly to your computer. No account required.

Question 14

Refund date passed and nothing hit the account — what do I check?

Accepted Answer

Pull REV-613 first. That is the ACH Rejected Refunds report in ACE Portal. Per CBP's CAPE documentation, REV-613 'highlights any refunds that have been rejected due to the recipient not being enrolled in ACH Refunds.' If your IOR shows up there, the transfer was attempted and bounced. The money is in a hold — CBP's FAQ: 'CBP will hold the refund until the ACH account information is available.' Fix the ACH Refund Authorization tab in your Importer sub-account, then email IEEPARefunds@cbp.dhs.gov with the claim number to re-initiate. If you are not in REV-613, check REV-615 for declaration status or look for an offset — CBP nets outstanding customs debts against the refund before payment, no advance notice.

Question 15

ES-003 shows a third of the rows after CAPE was accepted — is something wrong?

Accepted Answer

No. When CAPE accepts an entry, CBP removes the IEEPA Chapter 99 lines from that entry summary in real time. Per CBP's official guidance: 'ACE will update the appropriate entry summary lines by removing the IEEPA Harmonized Tariff Schedule Chapter 99 provision and the corresponding IEEPA duties.' Goods value still ties — only the 9903.01.xx duty lines come off. There is also a separate pattern: adding CAPE result objects to the ES-003 query restricts the output to the CAPE-eligible date range, making older entries disappear from view. Those entries are not processed, just filtered out. Run the query without CAPE fields to see them.

Question 16

ACH for duty payments is already set up — why did the refund get rejected?

Accepted Answer

ACH for paying duties and ACH for receiving refunds are two separate enrollments in ACE. Troutman Pepper flagged this in their CAPE guidance: 'ACH refund enrollment must be completed in ACE for a refund-specific bank account; having ACH set up only for duty payments is not sufficient.' The fix is the ACH Refund Authorization tab inside the Importer sub-account — separate from general ACH settings. If the transfer already rejected, that entry shows in REV-613. Update the tab, then email IEEPARefunds@cbp.dhs.gov with the claim number to re-initiate.

Question 17

What do Y and P mean in the CAPE Indicator column in ES-003?

Accepted Answer

CBP has not published official definitions. Based on consistent Phase 1 reports from customs brokers and importers: Y means the entry is processed through CAPE with a refund amount confirmed; P means the declaration was accepted and the entry is queued but reliquidation has not completed yet. Blank means either the entry was not included in a CAPE declaration or it was rejected before indicator status was assigned. To see these fields, add CAPE Indicator, Claim Status, Refund Amount, and Refund Date as result objects in the ES-003 report design.

Question 18

Can the government appeal and freeze CAPE refunds?

Accepted Answer

An appeal and a stay are two different things. The government has until approximately June 7, 2026 to appeal Judge Eaton's refund order to the Federal Circuit — that is the 60-day window from when the order was reissued in early April. An appeal alone does not pause CAPE. Refunds keep paying while an appeal is pending. A stay is a separate request that the government must make, and the Federal Circuit has to grant it — high bar. ACH payments that have already cleared are not clawed back regardless. Trade attorneys widely expect an appeal but note the stay is far from certain. Source: KJK, Holland & Knight, Snell & Wilmer, April 2026.

Question 19

Foreign company importing as IOR — how do we receive the CAPE refund?

Accepted Answer

Filing CAPE is open to any IOR regardless of where the company is based. The block is at payment: CBP requires a NACHA-compliant US bank account for ACH. Paper checks ended February 6, 2026. Two paths exist. Form 4811 is faster — CBP Form 4811 designates a US-based party, typically your customs broker or freight forwarder, to receive the refund on the IOR's behalf. That party needs their own ACE account with ACH refund enrollment active. Holland & Knight on CAPE payments: refunds go to 'the IOR or Form 4811 designee.' The second path is opening a US business bank account and enrolling it in the ACH Refund Authorization tab in ACE. File the CAPE declaration now either way — the 80-day window does not pause while the banking gets sorted.

Question 20

Can I resubmit entries that CAPE rejected?

Accepted Answer

Yes — if you can fix the reason for the rejection. Fixable rejections include entries with open protests or pending PSCs once those are resolved. Entries rejected for timing (liquidated more than 80 days) may be resubmitted in Phase 2. Not fixable: entries where PSC is blocked because a CAPE declaration already accepted them — that lock is permanent.

Question 21

My broker submitted a CAPE declaration without telling me — what now?

Accepted Answer

Check immediately whether the declaration was accepted or pending — if pending, contact your broker to withdraw. Verify where the refund is routing: ACH goes to the bank account on file for your IOR in ACE. Check the ACH Refund Authorization tab in your Importer sub-account. Once CAPE accepts an entry, PSC is blocked permanently under Error Code 864.

Question 22

My CAPE refund date passed but the money never hit my bank account — what do I check?

Accepted Answer

Run REV-613 first — the ACH Rejected Refunds report in ACE. If your IOR appears there, the transfer bounced and the money is in a hold. The most common cause: ACH for duties and ACH for refunds are separate enrollments. Fix the ACH Refund Authorization tab in your Importer sub-account, then email IEEPARefunds@cbp.dhs.gov with your claim number. Also check REV-603 for completed payments and REV-615 for entries still processing.

Question 23

Why did half my ES-003 rows disappear after CAPE was accepted?

Accepted Answer

Normal — CBP removes IEEPA Chapter 99 lines from accepted entries in real time. Goods value still ties; only duty lines come off. A second pattern: adding CAPE result fields to the ES-003 query restricts output to the CAPE-eligible date window, hiding older entries from view. Run without CAPE fields to see all entries. CAPE Indicator Y means refund confirmed, P means queued.

Pre-CAPE Audit

Frequently Asked Questions