Find Your CAPE Phase and Build the One-Column CSV CBP Accepts

You claim an IEEPA tariff refund by having the Importer of Record (IOR), or its authorized customs broker, upload a CAPE Declaration through the ACE Portal: a CSV with one header, Entry Number, one entry number per line, and no more than 9,999 entries per file. CBP validates the entries, reviews them, and pays the refund by ACH to the IOR’s U.S. bank account. Which entries you may list depends on the phase. Phase 1, open since April 20, 2026, covers unliquidated entries and entries no more than 80 days past liquidation. Phase 2, opened June 29, 2026, added reconciliation entries. Phase 3 opens October 6, 2026 for IORs that are plaintiffs in a pending Court of International Trade (CIT) case, covering entries liquidated more than 80 days ago. If your entries are unliquidated, you can file today.

Pick the entry’s liquidation status, litigant status and entry type; the phase and filing action update beside the controls.

This guide covers the data work: confirming the filer, classifying entries, building and validating the CSV, and tracking the outcome. It is not customs or litigation advice, and neither eligibility nor payment is guaranteed.

Which CAPE Phase Covers Your Entries

CBP is opening refund eligibility in stages. CBP’s IEEPA Duty Refunds page is the controlling source; the phase dates below come from that page, CBP’s refund fact sheet, and the September 2026 Thompson Hine update reporting CBP’s September 15 confirmation of the Phase 3 date.

Phase	Opened	Who can file
Phase 1	April 20, 2026	Unliquidated entries; entries no more than 80 days after liquidation
Phase 2	June 29, 2026	Reconciliation entries
Phase 3	October 6, 2026	IORs with a pending CIT case, for entries liquidated more than 80 days ago

Norton Rose Fulbright’s summary of the Phase 1 instructions reported exclusions for reconciliation-related entries, drawback claims, open protests, entries without an ACE liquidation status, certain AD/CVD entries, and finally liquidated entries. Phase 2 has since picked up reconciliation entries and Phase 3 picks up one slice of the liquidated population, so treat the Phase 1 exclusion list as history, not a permanent rule.

Two groups still have no announced route: entries liquidated more than 80 days ago where the IOR has no pending CIT case, and drawback or open-protest entries. Keep those in legal review rather than guessing a phase. Phase 3 is confirmed but not yet operational; do not assign an entry to it until October 6, and until the live CBP instructions match what was announced.

The 80-day count runs from the liquidation date. By a plain calendar count, an entry liquidated on July 1, 2026 reaches day 80 on September 19, 2026; CBP’s own count controls, so export before the window is close.

Who Can File and What CBP Needs Before You Upload

An importer-level CAPE request may be submitted by the IOR or its authorized customs broker. The filer needs an established, verified ACE Portal account, and the refund recipient must have U.S. bank information on file for ACH deposit. Confirm the broker’s authorization before anything is uploaded. CBP requires no supporting documents with the declaration.

Consumers cannot file. CBP refunds the IOR that paid the tariff, so if a carrier such as UPS was the IOR on a shipment, the refund goes to the carrier and the consumer’s route is the carrier’s reimbursement process (see the UPS note at the end).

Keep two datasets from the start: a private working ledger with entry facts, documents, eligibility notes, deadlines and payment reconciliation, and the CAPE export, which holds nothing but validated entry numbers. The separation is what keeps notes, amounts and bank details out of the upload.

Classify Every Entry Before Deciding What to List

Pull the full entry population first, from ACE reports, CBP Form 7501s or broker records, and only then decide what goes into a declaration. For each entry record the liquidation status, the liquidation date, days since liquidation, reconciliation and drawback flags, protest status, and any AD/CVD involvement. Those fields decide the route.

Entry category	Route	Next action
Unliquidated	Phase 1	Verify against current CBP rules, export
Liquidated ≤80 days	Phase 1	Confirm dates, export before day 80
Reconciliation-related	Phase 2	Check current reconciliation treatment
Liquidated >80 days, pending CIT case	Phase 3	Hold until October 6, 2026
Liquidated >80 days, no CIT case	Legal review	Entry-specific advice
Open protest or drawback	Exceptions	Withhold pending review
No ACE liquidation status	Data exception	Resolve status first

Do not force an ambiguous entry into eligible or ineligible. Put it in an exceptions queue with the reason, an owner, the guidance checked, the date checked and the next review date. Entries that pass day 80 while sitting in a queue are the expensive mistake here, so sort the queue by days since liquidation.

A private tracker with one row per entry needs: IOR, entry number, entry type, entry date, duty-deposit date, IEEPA amount, HTS code, liquidation status and date, days since liquidation, reconciliation and drawback flags, protest status, broker or carrier, route, provisional deadline, source checked, review date, declaration batch, validation result, submission status, payment status, interest, offsets and outstanding balance. Split the workbook into Entries, Supporting Documents, Deadlines, CAPE Batches, Validation Exceptions and Payments tabs so the export can be generated from a filter on Entries alone.

Supporting records such as Form 7501, commercial invoices, ACE reports and full entry packages stay in the ledger. CBP does not want them with the declaration, but they settle discrepancies later.

Calculate days since liquidation from the liquidation date and a review date, and label every deadline and recovery estimate as provisional. Entry status, controlling orders and later developments can change both the route and the amount.

What the CAPE Declaration CSV Must Contain

CBP requires a CSV listing eligible entry numbers, with no more than 9,999 entries per declaration; a filer may submit several declarations. Per the Norton Rose Fulbright summary of CBP’s instructions, the file has a single column: the first line is the header Entry Number, and every following line holds exactly one entry number. Entry numbers follow an 11-character alphanumeric rule. Nothing else goes in the file: no IOR name, amounts, liquidation dates, notes or tracker statuses.

A two-entry file therefore reads Entry Number on line 1, the first entry number on line 2 and the second on line 3. Download the current ACE template and match it rather than rebuilding the layout from a description, since phased functionality can change the format.

Before export from the working ledger:

• store entry numbers as text so leading zeros survive;
• trim surrounding spaces and remove blank rows;
• reject duplicates;
• check the 11-character rule on every row;
• for broker accounts, check entry-number filer-code alignment; for importer accounts, check that the account IOR matches the entry-summary IOR;
• include only entries approved for that batch; and
• split any population above 9,999 into multiple files.

After saving, open the CSV in a plain-text editor and confirm the header is exact, each later line holds one identifier, there are no formulas, extra columns, blank lines or delimiter artifacts, and the row count matches the approved batch. A spreadsheet’s own view can hide all of those.

Submit Through ACE and Log Each Milestone Separately

The IOR or authorized broker uploads the declaration in the ACE Portal. ACE validates the file and the listed entries, eligible entry summaries are queued for CBP review, and approved refunds are issued electronically. The public evidence does not pin down durable menu paths, screens, error codes or correction procedures, so follow the live CBP and ACE instructions rather than a static walkthrough.

For each declaration, log the submission date and time, any declaration identifier supplied, the submitting organization and user, acceptance or validation status, accepted-entry count and rejected entries if identified, the internal reviewer, the next review date and the related payment record. Do not assume CAPE will return row-level outcomes or partial-acceptance detail; the fields exist so you can capture whatever it does return.

A successful upload is not entry validation, CBP approval or payment. Track the four as separate milestones, and recheck CBP’s page immediately before each submission.

Deadlines and Payments to Track After Filing

CBP estimates processing within 60–90 days of accepting a declaration, with compliance review or liquidation status able to delay payment. That is an estimate, not a payment date.

CBP’s older IEEPA FAQ describes a general Post Summary Correction window ending within 300 days of entry or 15 days before scheduled liquidation, whichever comes first, and a general protest period of 180 days after liquidation. The FAQ itself points to the newer refund page for CAPE guidance, so treat those windows as reference points for the ledger, not as automatic instructions for every IEEPA entry. A PSC, protest or CIT action is neither universally required nor necessarily sufficient; the right route depends on liquidation status, prior filings and applicable orders.

Reconcile each payment at entry level, or at whatever allocation level CBP supplies:

Field	Purpose
Principal	IEEPA duty attributed to the refund
Interest	Interest identified in the payment
Offsets	Amount applied to other obligations
ACH amount	Cash received
Payment date	Bank settlement date
Outstanding balance	Expected amount not yet reconciled

Other duties, fees, offsets or entry errors can reduce final recovery, so keep the estimated IEEPA amount separate from the amounts accepted, approved and paid. When requirements change, rank current CBP instructions, CSMS notices, Federal Register notices and controlling court orders above older FAQs and law-firm summaries.

Share Progress Without Exposing Entry Data

The filing workbook stays private. If executives, clients or trade groups want visibility, publish a separate summary built only from aggregated or synthetic data: workflow stage, liquidation group, entry count and estimated IEEPA amount, plus submitted, paid and unresolved counts and a source-verification date.

Stage	Group	Entries	Est. IEEPA
Preparing CAPE	Unliquidated	24	$180,000
Exceptions review	Reconciliation	7	$42,000
Carrier handling	Carrier was IOR	11	$9,500
Legal review	Liquidated >80 days	5	$68,000

The figures are synthetic. Never publish real entry numbers, importer identifiers, invoices, bank details, tracking numbers or legal-review notes; a published data page is public, so it gets the sanitized table and nothing else.

What If UPS Was the Importer of Record?

UPS says it processes eligible CBP requests when it served as IOR and offers a shipment lookup for status and phase information. Customer reimbursement follows CBP’s payment and UPS’s own accounting, validation and reconciliation. A lookup result is not a guarantee of eligibility or payment; check UPS’s current IEEPA refund guidance.

Are Section 232 or Section 301 Duties Refunded Too?

No, not through this process. UPS and legal analyses both distinguish the struck-down IEEPA duties from Section 232 and Section 301 duties. An entry can carry liabilities under several programs, so keep the IEEPA amount separate when estimating recovery.

Is the October 6, 2026 Phase 3 Launch Confirmed?

CBP confirmed the date on September 15, 2026, per Thompson Hine’s report, for IORs that are plaintiffs in pending CIT cases and entries liquidated more than 80 days earlier. It is confirmed but not yet operational: file those entries from October 6, after checking that the live CBP instructions and any applicable court order match the announced scope.