CBP released its latest round of CAPE system updates in the first week of April, and there are meaningful changes that affect filing strategy, data preparation, and expected timelines. If you’re actively preparing for or already filing through CAPE, these updates require attention. If you haven’t started, they’re another reason why waiting is increasingly costly.
Here’s what changed, what it means, and what you should do about it.
Expanded Broker Registration
The biggest operational change this month is the expansion of CAPE portal access to approximately 1,200 registered customs brokerages, up from roughly 800 at the end of March. CBP has been processing broker registration applications on a rolling basis and accelerated the pace in early April.
What This Means
Broader broker access means more importers can file through their existing broker relationships without needing to engage a new broker solely for CAPE access. If your broker was previously unregistered, check whether they’ve gained access in the April expansion.
What to Do
Contact your customs broker and ask directly: “Are you registered for CAPE portal access?” If yes, great — confirm they’re familiar with the updated filing requirements (covered below). If no, ask when they plan to register. The registration process takes approximately 5-10 business days from application to approval.
If your broker has no plans to register for CAPE — some smaller regional brokerages are taking a wait-and-see approach — you have two options:
- Authorize a CAPE-registered broker to file on your behalf for IEEPA entries only, while maintaining your primary broker for ongoing business.
- Engage an advisory firm that coordinates CAPE filings through registered broker relationships.
Neither option requires you to change your primary customs broker. For background on how to coordinate between brokers, see our customs broker coordination guide.
Updated Data Validation Requirements
CBP published revised data validation specifications for CAPE declarations on April 1. These replace the preliminary specifications from March and include several important changes.
The Key Change: ACE Reconciliation
CAPE now performs automatic cross-validation against ACE entry records before accepting any declaration. Specifically:
- Entry numbers must exactly match ACE records
- Duty amounts claimed must not exceed the amounts recorded in ACE for the specified HTS codes
- Liquidation status as declared must match ACE’s current records
- Importer of record must match the filing entity or have documented authorization
Declarations that fail any of these validations are automatically rejected and returned for correction. Rejected declarations lose their queue position — when resubmitted, they enter the queue at the new submission date, not the original.
Why This Matters
Queue position is everything in CAPE. The system processes claims sequentially, and your position in the queue determines when your refund is processed. A rejection sets you back by however long it takes to identify the issue, correct the data, and resubmit.
The importers who will be affected most are those who prepared CAPE data from internal records or estimates rather than directly from ACE/ES-003 reports. If your data came from AP records or broker invoices rather than ACE extracts, there’s a meaningful risk of discrepancies that could trigger rejection.
What to Do
If you haven’t filed yet: Pull fresh ACE data through your broker and validate your CAPE declarations against it line by line before submitting. Our data preparation guide walks through the reconciliation process.
If you’ve already filed: Check your CAPE submission status. If your declarations were accepted, you’re fine. If they were rejected, identify the discrepancies immediately and resubmit corrected data. Every day of delay is a day further back in the queue.
If you’re using an advisory firm: Confirm they’re aware of the updated specifications and have re-validated your data accordingly. Any firm worth its fee should have caught this update and already acted on it.
New Entry Status Categories
CAPE now displays four status categories for submitted declarations, up from three previously:
| Status | Meaning | Importer Action |
|---|---|---|
| Accepted | Declaration passed validation, claim is in the processing queue | None — wait for processing |
| In Review | Claim is being actively processed by a CBP examiner | Respond promptly to any information requests |
| Additional Information Required | CBP needs documentation or clarification | Provide requested information within 30 days |
| Rejected | Declaration failed validation | Identify error, correct data, resubmit |
The new status — “Additional Information Required” — was previously combined with “In Review.” Breaking it out separately gives importers clearer visibility into what’s needed and introduces a 30-day response window. Failure to respond within 30 days may result in the declaration being placed on hold, further delaying processing.
Common Additional Information Requests
Based on early reports from brokers with claims in the “Additional Information Required” status, CBP is most commonly requesting:
- Proof of duty payment — bank statements or ACH confirmations showing the IEEPA duties were actually paid
- Commercial invoices — for entries where the country of origin or product classification is being verified
- Broker authorization — confirming the filing broker is authorized to file on the importer’s behalf
- Entry correction documentation — for entries that had prior amendments or Post-Summary Corrections
Having these documents organized and accessible before you file prevents delays when the request comes. The documentation requirements guide lists everything CBP may ask for.
Processing Metrics: What the Numbers Show
CBP hasn’t published an official processing dashboard (despite requests from industry groups), but the data we can piece together from broker reports and public filings tells a story.
Declaration Volume
| Week | Declarations Submitted (cumulative) | Weekly New |
|---|---|---|
| March 1-7 | ~12,000 | ~4,000 |
| March 8-14 | ~18,000 | ~6,000 |
| March 15-21 | ~23,000 | ~5,000 |
| March 22-28 | ~27,000 | ~4,000 |
| March 29 - April 4 | ~45,000 | ~18,000 |
The spike in the last week reflects two factors: the broker registration expansion gave more filers access, and the approaching end of Q1 motivated many importers to file before quarter-end reporting.
Refund Issuance
As of early April, CBP has issued approximately $890 million in IEEPA refunds. That’s less than 1% of the estimated $166 billion total, but the rate is accelerating. March alone saw more refund value issued than January and February combined.
The fastest-processing claims share common characteristics:
- Clean, complete data matching ACE records exactly
- PSC-eligible unliquidated entries
- Single broker filing with no complications
- Small to moderate portfolio size (under 50 entries)
Larger, more complex portfolios are taking longer, consistent with the expected processing pattern. For analysis of what this means for specific timeline projections, see our Q2 status report.
CAPE Technical Updates
Several technical improvements were deployed in the April update:
Batch Upload Support
CAPE now supports batch upload of multiple entry declarations in a single submission, using a standardized CSV template. Previously, each entry had to be declared individually. This is a significant efficiency improvement for importers with large portfolios.
The CSV template is available for download in the CAPE portal. It requires specific column headers and data formats — deviations will cause the batch to reject entirely, not just the problematic entries. Review the template carefully before preparing your batch file.
Status Notification System
Filers can now opt into email notifications for status changes on their declarations. When a declaration moves from “Accepted” to “In Review,” or when additional information is required, the designated email address receives an automatic notification.
Enable this immediately. Without it, you’re checking CAPE manually for status updates — which means delays in responding to information requests that could push your claim to the back of the queue.
Error Reporting Enhancement
The CAPE rejection notification now includes specific field-level error codes identifying exactly which data elements failed validation. Previously, rejections included only a general error message, requiring filers to review the entire declaration to find the issue.
This improvement should significantly reduce the time from rejection to corrected resubmission.
Frequently Asked CAPE Questions
Since the April updates, we’ve received a surge of questions from importers. Here are the most common.
”My broker submitted my declaration but I can’t see it. How do I check status?”
As an importer, you don’t have direct CAPE portal access — your broker files on your behalf through their ACE login. Ask your broker to check the status and report back. With the new email notification feature, your broker can add your email address to receive status change alerts directly.
”My declaration was rejected. Will I lose my place in line?”
Yes, unfortunately. A rejected declaration loses its original queue position. When you resubmit with corrected data, the declaration enters the queue at the new submission date. This is why data validation before filing is so critical — a rejection can cost you weeks of queue position.
”Can I file some entries now and add more later?”
Yes. You can submit CAPE declarations in batches. Many importers file their cleanest, best-documented entries first and add more complex entries in subsequent submissions. Each declaration gets its own queue position, so earlier filings will be processed first.
”My broker says they’re not ready for CAPE. Should I wait?”
No. If your broker isn’t ready — either because they haven’t registered or because they’re unfamiliar with the system — explore alternatives. You can authorize a second broker for CAPE-specific filings, or your advisory firm may coordinate with a registered broker on your behalf. Don’t let broker readiness delay your filing when other options exist.
”What happens if CAPE goes down or has technical issues?”
CBP has not published a formal service level agreement for CAPE uptime. In the first month of operations, users reported brief outages and slow response times during peak filing hours (typically Monday mornings and Friday afternoons). These were resolved within hours, not days. Filing during off-peak hours — Tuesday through Thursday, mid-morning — has been more reliable.
”Should I wait for the batch upload feature to be fully tested before using it?”
The batch upload feature is operational now. If you have a large portfolio, it’s the most efficient filing method. However, test with a small batch (5-10 entries) before uploading your full portfolio. This catches formatting issues without risking rejection of your entire declaration set.
CAPE Data Formatting Guide
For importers preparing batch upload files, here’s a quick reference on the data formatting requirements that trip up the most filers.
Critical Formatting Rules
| Field | Format | Common Error |
|---|---|---|
| Entry Number | 11-digit numeric, no dashes or spaces | Including dashes (XXX-XXXXXXX-X) |
| Entry Date | YYYY-MM-DD | Using MM/DD/YYYY format |
| HTS Code | 10-digit with period separators | Missing or extra digits |
| Duty Amount | Decimal, no dollar sign or commas | Including ”$” or ”,” characters |
| Country of Origin | 2-letter ISO code | Using full country name |
| Liquidation Status | ”U” or “L” | Using “Unliquidated” or “Liquidated” |
One formatting error in a batch upload rejects the entire batch. Check your CSV file against these specifications before uploading.
What These Updates Mean for Your Strategy
If You’re Prepared and Ready to File
File now. The expanded broker access and batch upload support make filing easier than it was last month. Clean data that matches ACE records will pass the new validation requirements without issue. Every day you wait is a day you’re behind the 45,000+ declarations already in the queue.
If You’re Still Preparing Data
The updated validation requirements make data quality more important than speed. Don’t rush a filing that will fail validation — a rejected declaration actually puts you further behind than a slightly delayed but accurate one. Spend the time to reconcile your data against ACE before submitting.
If You Haven’t Started
The gap between early filers and non-filers is widening. Early filers are already receiving refunds. Non-filers haven’t even entered the queue. The cost of waiting increases with every monthly CAPE update, because every update brings more filers into the system ahead of you.
Your first step is still the same: get an Impact Assessment to understand your exposure, your entry statuses, and your optimal filing strategy. The assessment process runs parallel to CAPE preparation — you can be gathering data, validating entries, and getting strategic guidance simultaneously.
If You Have Entries at Risk
The updated 30-day response window for “Additional Information Required” status means that having documentation organized in advance isn’t just helpful — it’s time-critical. If CBP requests information and you can’t respond within 30 days, your claim goes on hold with no clear timeline for resumption.
Impact on Recovery Strategy: Updated Recommendations
The April CAPE updates affect optimal recovery strategy in several ways.
PSC-Path Entries: File Immediately
With PSC processing averaging approximately 35 days through CAPE, there’s no reason to delay filing unliquidated entries. The faster you file, the sooner you receive your refund. And with entries potentially liquidating at any time — closing the PSC window — prompt filing protects against losing this fastest recovery path.
Protest-Path Entries: File Protests Now, CAPE Declarations in Parallel
File formal protests through your broker immediately to preserve your rights within the 180-day window. Simultaneously, prepare CAPE declarations for the same entries. As CAPE’s protest processing matures, having your data in the system positions you for faster resolution.
CIT-Path Entries: Patience Required
For entries past the protest window, CAPE’s CIT integration is still developing. Continue pursuing CIT litigation through your trade attorney and expect CAPE to handle the refund processing once the court order is obtained. Timeline: late Q3 2026 at the earliest for full CIT-path CAPE processing.
Claim Sale Entries: Act While Market Favors Sellers
The improved CAPE processing data has boosted claim sale pricing. If you’re considering selling complex or at-risk entries for immediate capital, current market conditions are favorable. Pricing at 82-90% for clean portfolios represents a meaningful improvement from February levels.
Looking Ahead: May 2026 Expectations
Based on CBP communications and court filings, here’s what we expect to see next month:
- Additional broker registrations as the remaining 25-30% of brokerages complete the process
- First large-portfolio refunds as declarations from major importers move through the processing pipeline
- Possible CIT ruling on the timeline motion filed by the 40-importer group (which could establish mandatory processing deadlines)
- Updated interest rate from the IRS for Q2 2026, affecting statutory interest calculations
We’ll cover all of these in our May roundup. To stay current between monthly updates, see our weekly IEEPA briefing.
Get your free Impact Assessment →
The CAPE system is live and processing claims. The question isn’t whether your refund is coming — it’s when, and that depends on your filing position. Request your Impact Assessment today, get your data validated, and file with confidence. Every week of delay is now measurable in real dollars and real queue positions.
