u/Constant_Juice_5852

https://es-003.com/rev603-doesnt-match-bank

ES-022 lists refund amount and interest amount as separate columns. Treasury can wire them in separate ACH transmissions, sometimes a few days apart.

If your deposit matches the principal but not the principal-plus-interest total, the interest is in flight, not lost.

Per 19 CFR § 24.36, interest accrues from deposit date to refund date at the IRS quarterly rate. CSMS #68340863 confirms this applies to CAPE.

Quick check: duty × current IRS quarterly rate, prorated by days from deposit to refund. Should land within a few dollars of what ES-022 shows.

If the second ACH still doesn't show after a week, check REV-603 - a "Funds Diverted" status means it's a § 24.72 offset, not a timing gap.

source: https://es-003.com/cape-refund-came-short

A few of these have been showing up in TREAS 449 and partial-refund threads. Five distinct mechanisms, each visible in a different place.

Funds Diverted under 19 CFR § 24.72. CBP-level offset against an outstanding CBP debt. REV-603 Refund Secondary Status shows "Funds Diverted" (column added in CSMS #68536553, May 4). Bank still shows CBP TREAS 310.

Treasury Offset Program under 31 CFR § 285.5. Treasury-level offset against unrelated federal debt — defaulted SBA loans, IRS back taxes, federal student loans, child support. Bank code switches to TCS TREAS 449. TOP IVR 800-304-3107 identifies the creditor agency.

Entry-level netting under 19 CFR § 159.1. Reliquidation nets all over- and under-payments across the whole entry, not just IEEPA. MPF or Section 301 underdeposit pulls the IEEPA refund down.

Principal and interest in separate ACH. ES-022 lists them as separate columns. Treasury can wire them days apart.

Partial declaration acceptance. Per CSMS #68340863, ACE drops failed entries and keeps processing the rest. CAPE Tab shows per-entry rejection reasons.

Diagnosis order: bank code (310 vs 449) → REV-603 Secondary Status → ES-022 vs deposit total → CAPE Tab.

https://preview.redd.it/292s8czqiiyg1.png?width=2938&format=png&auto=webp&s=29a4a218847bb93425d728e425bacf4d4152cbf1

IEEPA refunds include interest under 19 U.S.C. 1505. There is a trap though.

Under 19 CFR 24.36(a)(3), amended via Federal Register 2025-24171: if CBP certifies the refund and initiates the transfer but cannot complete it because the recipient has no ACH banking info on file, interest stops accruing from that moment. Not when the issue gets fixed. From when CBP first attempted.

The refund sits in the REV-613 ACH Rejected Refunds report earning nothing.

At 6% annualized, that's roughly $1,000/month on a $200k refund.

Set up ACH before filing. Not after.

resource: es-003.com/audit

The first 3 characters of an entry number are the filer code.

Community-reported, not an official CBP registry:
SCS = FedEx Logistics
1UZ = UPS Supply Chain Solutions

When a carrier filed the entry, the CAPE refund goes to their ACH account by default. The importer gets it from the carrier, not from CBP directly. Unless a Form 4811 designating a different recipient was filed first.

Worth confirming before submitting CAPE.

resource: es-003.com/audit

The first 3 characters of an entry number are the filer code.

Community-reported, not an official CBP registry:
SCS = FedEx Logistics
1UZ = UPS Supply Chain Solutions

When a carrier filed the entry, the CAPE refund goes to their ACH by default. The importer gets it from the carrier, not from CBP directly. Unless a Form 4811 designating a different recipient was filed beforehand.

Worth checking before submitting, especially for shipper accounts where the carrier handles customs.

Anyone dealt with carrier-filed entries yet? Curious how the pass-through is working in practice.

source: es-003.com/deadlines

Phase 1 accepts entries liquidated within the preceding 80 days from the actual filing date. Not from April 20. From whenever the Declaration gets submitted.

A February 20 entry is 70 days old today. Wait two weeks and it crosses 80. Gone.

February 2026 liquidations are at the edge. Some have already crossed it.

Phase 1 accepts entries liquidated within the preceding 80 days from the actual filing date. Not from April 20. From whenever the Declaration gets submitted.

An entry that liquidated February 10 is still eligible today (79 days). File on May 12 and that same entry is 93 days old. Rejected. Form 19 territory.

January and February 2026 liquidations are at the edge of the cutoff right now. Some have already crossed it.

Resource: https://es-003.com/rev-reports-guide

Filed April 20, accepted, all three REV reports show No Data. Common pattern this week.

REV-613 (ACH Rejected Refunds): blank means no rejection queued. Good.

REV-603 (Trade Refund): runs after reliquidation, not acceptance. Next business day for already-liquidated, 45 days for unliquidated, per CSMS #68340863.

REV-615 (Trade CAPE Detail): effective April 20 per CBP IEEPA FAQ. First to populate.

Run all three from the Importer sub-account. TOP returns blank regardless.

REV-603's Refund Secondary Status shows "Funds Diverted" when an offset under 19 CFR § 24.72 hits. No error message.

Filed CAPE, accepted, all three REV reports blank. Same question across threads. Empty isn't denied.

REV-613 (ACH Rejected Refunds): if it's empty, no rejection is queued. That's the right outcome.

REV-603 (Trade Refund): per CBP, "covers successful refunds." It runs after reliquidation. Already-liquidated entries reliquidate next business day per CSMS #68340863. Unliquidated entries hit the 45-day target from acceptance.

REV-615 (Trade CAPE Detail): live since April 20 per CBP IEEPA FAQ. Entry-level plus consolidated. Populates first.

All three live in the Importer sub-account. Pulling from TOP returns nothing.

REV-603's Refund Secondary Status flips to "Funds Diverted" when CBP applies an offset under 19 CFR § 24.72. No error, no notification.

Past day 45 with REV-615 still blank: IEEPARefunds@cbp.dhs.gov with the claim number.

resource: https://es-003.com/cape-offset-risk

Three things can reduce or zero out a CAPE refund. None throw an error code.

Offset under 19 CFR § 24.72. Per CBP's IEEPA FAQ, outstanding CBP debts get applied to the refund first; whatever's left gets paid. REV-603 shows "Funds Diverted." Common situations: AD/CVD adjustments, open bond claims, prior reliquidations that came out underpaid.

Netting under 19 CFR § 159.1. Same CBP page calls for "netting of all over- and under-payments for the entire entry" at reliquidation. Whole entry recalculation, not just the IEEPA line. MPF rounding, Section 232 misclassification, any underpaid line gets pulled in. CAPE filing requires agreement, no opt-out.

Appeal-side risk. No appeal filed as of April 28 per Fortune. The 60-day window from the April 7 Euro-Notions order closes June 6-8. An appeal alone doesn't pause CAPE per Skadden and Sullivan & Cromwell; a stay needs to be filed and granted separately. Snell & Wilmer flagged that cleared ACH refunds aren't formally protected from later government recoup efforts.

https://preview.redd.it/blt48rt70cyg1.png?width=2940&format=png&auto=webp&s=8db61f41b229a95fae451af910257d2e9bafec78

ES-003 with CAPE result fields shows multiple Claim Numbers on some entries. Two patterns.

Same Claim Number across several entries with identical totals: that's CBP's consolidation logic. Refunds get grouped by IOR (or Form 4811 designee) and liquidation date. REV-615 has the entry-level breakdown underneath.

Different Claim Numbers on one entry: per CSMS #68340863, "each entry may only be submitted on one accepted CAPE Declaration." Only one is accepted. The rest are rejected duplicates that ES-003 still records. This is where unauthorized filings surface. FedEx and UPS both publicly stated they're filing for entries where they served as broker or IOR.

Refund routing follows CF-7501 Box 12. Carrier name there: refund hits the carrier's ACH, then to customers per their public commitments (intent language, not contractual). Importer name: refund routes to the importer's ACH or Form 4811 designee.

PSC blocks once CAPE accepts the entry: Error 864 per CSMS #68397097. To identify who filed, email IEEPARefunds@cbp.dhs.gov with the entry numbers.

First batch was April 20 filers, re-liquidated April 21, refund date May 5. Some will land. Some won't.

REV-613 first. ACH Rejected Refunds report. CBP's CAPE TIN: "highlights any refunds that have been rejected due to the recipient not being enrolled in ACH Refunds." Money is in a hold, not gone. CBP's FAQ: "CBP will hold the refund until the ACH account information is available." But they don't auto-retry. Fix the enrollment, then email IEEPARefunds@cbp.dhs.gov with the claim number.

The part most people don't catch: ACH for duty payments and ACH for refunds are separate enrollments in ACE. An IOR who's been paying duties via ACH for years can still land in REV-613 because the ACH Refund Authorization tab in the Importer sub-account was never configured. Troutman Pepper specifically flagged this in their CAPE guidance.

REV-603 after that. Trade Refund Report, successful ACH payments. If the refund shows here with a payment date but the bank account has nothing, issue is banking-side. Wrong account, closed account, deposit going somewhere nobody is monitoring.

REV-615. CAPE Detail Refund Report. If it still shows entries processing and REV-613 is clear, it's timing. Unliquidated entries target 45 days from acceptance for liquidation. No real Refund Date until that happens.

Offset is the fourth thing and doesn't show as an error. CBP nets outstanding customs debts before payment, no advance notice. Refund lower than expected or zero with no error anywhere is usually offset.

es-003.com/june-7-appeal-risk

Most coverage treating the appeal deadline like it automatically freezes refunds. That's not how it works.

The June 7 deadline is approximately when the 60-day window closes for the government to appeal Judge Eaton's refund order to the Federal Circuit. Not a fixed statutory date. KJK, Holland & Knight, Flexport, and Snell & Wilmer all cite "approximately June 7" based on the 60-day calculation from when the order was reissued in early April. Practitioners widely expect an appeal.

Appealing and getting a stay are two separate things. An appeal alone doesn't pause CAPE. CBP keeps processing. Refunds keep paying. A stay is a separate request the government has to make alongside the appeal, and the Federal Circuit has to actually grant it. ACH payments that already cleared don't get clawed back regardless.

The expected legal theory comes from Trump v. CASA Inc., the 2025 Supreme Court ruling that curtailed nationwide injunctions. Government would argue CIT can't issue relief extending to 330,000 importers who never filed suit. Judge Eaton's order anticipated this and points to CIT's unique statutory nationwide jurisdiction under 28 USC 1581(i). Open question, no appellate court has resolved it.

Practical read: importers with their own CIT action under 1581(i) have an enforcement layer that CAPE alone doesn't. Neville Peterson flagged CAPE directly: it has "no statutory right of review and no independent judicial enforcement mechanism." Getting acceptance before June 7 puts a filing further into processing. Doesn't guarantee payment completes before any potential stay, but it's better math than filing after.

Foreign companies that imported as IOR run into this at the payment step. Declaration accepted. Entries reliquidate. Refund Date shows in ES-003. Then nothing arrives.

CBP requires a NACHA-compliant US bank account to pay. There's no fallback. Paper checks ended February 6, 2026. Baker Tilly flagged this specifically in their CAPE guidance: ACH "can create challenges for non-resident importers (NRIs) that do not have U.S. banking infrastructure in place. In these cases, even approved claims may face delays at the point of payment."

Two paths to fix it.

Form 4811 is the faster one. CBP Form 4811 (Special Address Notification) designates a US-based party to receive the refund on behalf of the IOR. Usually a customs broker or freight forwarder with their own ACE account and ACH enrollment. Holland & Knight on how CAPE pays: refunds go to "the IOR or Form 4811 designee." Get the pass-through terms in writing before filing the form.

US business bank account is the other path. Works if there's a US legal entity. Some institutions open accounts for pure foreign entities with EIN and incorporation docs, though requirements vary. Confirm NACHA ACH receipt support with the bank before completing ACE enrollment.

File the CAPE declaration regardless of which path is chosen. The 80-day window doesn't pause. Accepted declaration with payment on hold is better than entries that aged out of Phase 1.

If the refund already rejected, REV-613 in ACE shows it. Fix the enrollment, then email IEEPARefunds@cbp.dhs.gov with the claim number to re-initiate. CBP holds the funds, doesn't lose them.

https://preview.redd.it/w6jx93kr4xxg1.png?width=2940&format=png&auto=webp&s=202c6c8ffe0f279d729bcff94b89eb3bbc96b1b9

Ran ES-003 last week, all IEEPA lines visible. Ran it today, 9903.01.xx lines are gone, report is a third of what it was. Filters unchanged.

CBP's official guidance on what CAPE does: "ACE will update the appropriate entry summary lines by removing the IEEPA Harmonized Tariff Schedule Chapter 99 provision and the corresponding IEEPA duties, resulting in an updated version of the entry." Missing rows are accepted entries. The goods value still ties. Only the duty lines come off.

Two patterns get confused here:

Pattern 1 - IEEPA duty rows gone from existing entries. That's CAPE processing, not data loss.

Pattern 2 - added CAPE result objects to the query and now older entries disappeared entirely. The CAPE fields act as a date filter that restricts output to the CAPE-eligible window. Those 2023 entries aren't processed, they're filtered out of view. Run the query without CAPE fields to see them.

To confirm processing status, add these result objects: CAPE Indicator, Claim Status, Refund Amount, Refund Date. Based on Phase 1 community reports (CBP hasn't published official definitions), Y means the entry is processed with a refund amount confirmed, P means accepted and queued. Blank means either not in the declaration or rejected before indicator status was assigned.

Pre-CAPE export matters now. Live ES-003 no longer shows the IEEPA duties that were refunded. Without a saved export, reconciling the lump sum runs backward through CF-7501s and broker records.

Entries filed through UPS World Ease show a carrier filer code (community reports indicate SCS). CAPE returns ACCOUNT MISMATCH on submission from the importer's own ACE account. It looks like a hard block but it splits in two depending on who's actually IOR on the CF-7501.

If UPS is IOR on the entry, the importer can't file CAPE on these. Per CBP, only the IOR or the original filing broker can submit. UPS has committed publicly: "For Phase One shipments where UPS was the IOR, we will work to request and retrieve IEEPA tariff refunds from CBP on our customers' behalf." Wait for UPS to file and distribute.

If the importer's company is IOR and UPS filed as broker, the importer can file from their Importer sub-account. ACCOUNT MISMATCH in this case means the IOR number in ACE doesn't match what's on the entry summary exactly. Different EIN format, different name version, wrong sub-account. ACE validates against the IOR number when filing from an Importer account.

Check: pull the CF-7501, Box 12. Carrier name there means UPS is IOR. Importer's company name means the mismatch is fixable through ACE configuration.

If the 80-day window is closing and UPS isn't moving fast enough, UPS as broker of record can file CAPE on the importer's behalf. Refund goes to the importer's ACH or Form 4811 designee.

Full breakdown: es-003.com/ups-world-ease-account-mismatch

https://preview.redd.it/xwksi2o8lqxg1.png?width=2940&format=png&auto=webp&s=80fc623baffdd80088dcd09bf9986cc6f438652a

Once CAPE accepts an entry, Post Summary Corrections are blocked until liquidation — Error 864, CSMS #68397097. Any data issue on that entry summary is frozen. 4811 not set up beforehand? Locked too.

Four things that close eligibility before you even open the portal:

Liquidation cutoff. Phase 1 takes entries liquidated within 80 days of filing. Anything older needs Form 19 first - and if that 180-day window is closing, the protest goes in before CAPE does.

Open or suspended protest. CBP excludes these explicitly. Clients frequently have no visibility into what their previous broker left open. Ask before you build the batch.

Entry type. TIB (23), Reconciliation (09), Drawback (47), Duty Deferral - excluded outright. Pulling all China entries by date range without filtering by type puts these in the declaration.

Rate period. 9903.01.63 at 125% only ran April 10/May 13, 2025. 9903.01.24 changed November 10, 2025. Entries near those dates need the entry date confirmed before the refund amount means anything.

CBP error table: cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds

resource: liberefund.com

Phase 1 accepts entries liquidated within 80 days of your filing date. Past that - permanently ineligible. No appeal, no override. CBP lays out the full eligibility rules at cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds - including what counts as liquidated and what doesn't.

If you're past the 80-day window but still inside 180 days from liquidation, one path remains: Form 19 protest under 19 U.S.C. §1514. File the protest first, not the CAPE declaration.

Three more things that block eligibility before you know it:

Open or suspended protest on the entry. CBP excludes these explicitly. A lot of importers have protests from prior disputes sitting open and have no idea.

Entry type. TIB (23), Reconciliation (09), Drawback (47), Duty Deferral - excluded outright. If your broker pulls all China entries without filtering, these end up in the declaration.

Rate period. 9903.01.63 at 125% ran April 10–May 13, 2025 only. 9903.01.24 had a rate change November 10, 2025. Entries near those dates need the entry date verified or the refund amount is wrong.

Once CAPE accepts an entry, PSC is locked until liquidation (Error 864, CSMS #68397097). Data errors get corrected before you file, not after.

Full breakdown of each block with what's still fixable: es-003.com/cape-permanently-blocked

Everyone filing CAPE for the first time is quoting the same number: 60 to 90 days. That's what CBP says.

Entries filed on April 20 are showing Refund Date: May 5 in ACE. 15 days...

Ace report

If you haven't filed yet, you still have time. Pull your ES-003, check which entries are eligible, and submit. The 180-day protest window for older liquidated entries is a hard deadline. No extensions.

https://es-003.com/cape-errors-guide

Been getting the same two questions in my DMs so writing this up.

GOODS VALUE AMOUNT NOT ALLOWED ON IEEPA HTS LINE

Same as the GDS_VAL_AMT error, different wording. Your goods value ended up on the Chapter 99 IEEPA line instead of the Chapter 1-97 commodity line. Per CSMS #68340863 item k, entered value goes on Chapter 1-97. That's it.

Fix is a PSC. But check your Claim Status first.

If this error is showing, your entry was rejected, not accepted. Error Code 864 (the PSC block) only kicks in on entries that were accepted into CAPE. Rejected entries don't have that block. The second your entry shows "ENTRY SUMMARY UPDATED," that window closes permanently, so check before you do anything.

One more thing: the PSC you're filing corrects a data error on the original entry, not an IEEPA refund request. CBP prohibits PSCs filed to initiate IEEPA refunds, so frame yours as a correction. After it processes, resubmit the entry on a new CAPE Declaration.

HTS RELATIONSHIP/SEQUENCE MISMATCH

Mostly FTZ Type 06 weekly entries. These filed fine originally, CBP accepted them at the time. But CAPE runs different validation logic and now it's flagging a sequence issue between the IEEPA Chapter 99 code and the underlying commodity line.

Not in CBP's FAQ. No confirmed workaround. Don't resubmit the same file, the problem is on their side, not in your CSV. Email IEEPARefunds@cbp.dhs.gov with your entry numbers and the exact error text, and ask them to confirm they logged your case. Phase 2 is expected to cover this type.

Full list of error codes from Day 1 is here: reddit.com/r/CustomsBroker/comments/1sr31wi

cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds