Why 4.36 Million IEEPA Refund Entries Failed Validation—And How to Fix Yours
While U.S. Customs and Border Protection (CBP) has accepted a staggering $104.29 billion in potential and certified IEEPA tariff refunds across 18.1 million entries since launching the CAPE portal in April, there is a major catch. Approximately 4.36 million entries included on CAPE declarations have completely failed entry-level validations and were rejected.
If your entries are rejected, they are removed from the declaration, and you will not receive your refund unless the issues are successfully resolved and the entries are resubmitted.
The Top Three Reasons IEEPA Entries Fail Validations
According to CBP’s report to the U.S. Court of International Trade (CIT), the vast majority of the 4.36 million failed entries were rejected for three specific reasons:
Past the 90-Day Authority: The entry date is past CBP’s 90-day re-liquidation authority.
Missing Chapter 99 HTSUS Number: The entry did not contain the specific Chapter 99 Harmonized Tariff Schedule (HTSUS) number that was originally used to assess the IEEPA duties.
Duplicate Filings: The entry was already submitted on a prior CAPE declaration.
Other ACE Validation Pitfalls
Beyond these top three errors, several other strict rules will cause automated rejections in the ACE Portal. For instance, entries with open or suspended protests will fail validation. However, if a protest was filed solely for IEEPA refund purposes and the entry is within 80 days of liquidation, the protest can be withdrawn so you can submit the entry in CAPE for faster processing.
Additionally, entries subject to Antidumping or Countervailing Duties (AD/CVD) in a pending liquidation status are ineligible. Simple file errors, such as corrupted CSV files or incorrectly formatted entry numbers, will also trigger an immediate rejection of the entire declaration.
How ACM Can Help You Recover Your Refunds
Recovering IEEPA duties requires clean data and precise filing. That is where ACM's expertise comes in.
Our Expected IEEPA Assistance Commitment: Navigating the strict validations and constantly evolving policies of the ACE CAPE portal can be complex. At ACM, our team specializes in resolving validation errors and managing your CAPE declarations from start to finish. Contact ACM today to secure the refunds your business is owed.
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