CAPE Explained: Refunds, Common Issues & Next Steps for Importers

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Brian Chapman

Hello, everybody. Thank you for attending today's tariff trends webinar. My name is Brian Chapman, and I'm a senior trade advisory associate here at Flexport. We have a lot of content to get to, but before we begin, I'd like to go over a few housekeeping items. On your screen, you'll see a sidebar on the right of the main stage where you can submit questions. At the end of the presentation, we will host a q and a and answer a few of the audience's questions. So be sure to get your questions in early. In the same sidebar, you'll see a tab called docs. This is where you can download a copy of today's slides and find other helpful resources like our tariff simulator and tariff refund calculator. You can also find a link to register for tomorrow's CPSC e filing webinar where where we will also cover the latest section two thirty two and three zero one updates. Above your screen, you'll see a button labeled audit your customs broker. This is one for our newest AI tools that runs a compliance audit under historical customs entries. It can help identify entries with tariff stacking issues and estimate duties you may have over or underpaid. Click the button above your screen to get started. And a brief legal note. Please keep in mind that all information provided in this session is based on the situation at this current time and may not be customized to your specific business requirements. We always recommend reaching out to a Flexport expert to discuss your particular situation. And also joining me to me today is my colleague, Callum Coulter, who is also a senior trade advisory associate here at Flexport. Hello, Callum. And today's agenda, we're, kicking things off with what you do prior to submitting your CAPE submission. Then we'll kinda walk you through what to expect after the CAPE submission and monitoring your refund. Lastly, we'll cover some CIT and CBP updates and followed by a few resources, and then we'll close it out with answering some of your questions in our q and a. And jumping right in, I'm gonna pass it to Callum.

Calum Coulter

Thank you, Brian. We've got quite a bit to discuss today, so let's go ahead and get started. First section here, we're gonna talk about what to do before you proceed with a CAVE submission, a couple of absolute must dos, and then a couple of recommendations that I'd have for validating your data before proceeding. So first, how to prepare, you're gonna have to get your ACE account set up. If you don't already have an ACE account set up, please begin getting that established right away. The KACE submission portal all sits within your ACE account, so you absolutely will need an ACE account on file, in order to receive the IEPRA refunds. If you don't already have an ACE account set up, try to begin getting that established right away, with the refunds moving, with the KAPE process these days. It seems like there's quite a bit of request going through to CBP to get these accounts established. Last we were hearing it was taking roughly two to three weeks to get these, ACE accounts set up. So if you don't already have that on file, go ahead and get started right away. On the other side of that, if you are having ACE account issues, if you're locked out of your account for one reason or another or the top account owner left the company and you need to get back into the ACE account, go ahead and reach out to the ACE support desk. There's an email and a phone number listed on the screen. Give them a call, send them an email, and they should be able to help you out. Much like establishing the ACE accounts initially, they're receiving quite a few requests these days with all of the movement, with IEPA duties, and refunds moving through Cape. So we what we've been hearing from importers is that some folks are having a little trouble getting a hold of somebody, during regular business hours or in the middle of the day. So again, the support desk is monitored twenty four hours a day. So if you're not able to get a hold of anybody, and you're sitting on the West Coast, I would really encourage you to, give them a call after hours or in, off peak hours, and you will likely have some more success getting ahold of somebody. Something else we've been hearing from importers, is that you can elect to receive a callback. And, again, VA support desk is monitored twenty four hours a day, and they're working twenty four hours a day even if you were not. So I have heard from quite a few importers that they're receiving calls back in the middle of the night and are missing those because they're not expecting them. It's just something to be aware of. Okay. Second absolute must do here, is check the ACH refund authorization tab in the ACE account. Ensure that this is fully set up and the information is accurate. If you do not have your ACH refund authorization tab set up in ACE, you will not be receiving refunds. CBP is not going to send you a check if you don't have that information filled out. The refund will be rejected and will be stalled until you get that information set up. So please, before you proceed with a CAPE submission, ensure that the ACH bank account information is on file, and that you're fully set up there. If for some reason you, missed that on the first round and you submitted CAPE, it was accepted and a refund was issued, that refund would be rejected. And in order to get that resolved, you'll need to get the information set up in ACE, and then request for the, refund to be reached, Gregor. Last we heard, it was taken about four to six weeks to have the refunds reissued from, once the original refund, was rejected. So try to avoid that if at all possible and ensure that all of this inform Okay. With that, you have your ACE account set up, you're fully established. Couple of things you're really going to want to do before you proceed with the CAPE declaration, is really just data validation. So first, you need to download your data from ACE so that you can review it. There are a couple of prebuilt reports that are very helpful. The ES003 is a good line level report that has quite a bit of good information in there. That said, I would really encourage all of you to utilize the ACE customizable reports. You can build these out to include whatever data elements you feel are relevant for your specific circumstances. It takes a little bit of time to get used to the portal and get the reports built up from scratch, but you will get quite a bit more substantial information with the customizable reports. And once set up, you can also schedule these reports to be sent to you on a regular basis. So we'd really encourage you all to do so. Next item, very important. Once you get these ACE reports built up, please save copies of these offline and ensure that these reports give you the ability to identify expected refunds. Flexport does have a good tariff refund calculator tool that I would encourage you all to use as well, but ensure that you have reports on file before proceeding with the CAPE submission. What we've been seeing is that almost immediately after CAPE acceptance, the IITA HTS codes are being removed from the ACE reports. So if you don't have a good idea of what your expected IITA refunds will be and don't have these reports on file and you proceed with a CAPE upload, you're going to lose quite a bit of visibility about what's the refund amounts you should be expecting will be, and it'll be quite a bit more difficult to reconcile the refunds you're receiving, once those funds do start moving in your direction. So, again, set up some reports, download them, save them offline, ensure you have the good, the relevant visibility before proceeding. Next item here is to go ahead and do a full audit of your entries to ensure accuracy and maximize refunds. If we're thinking back to early twenty twenty five when all of the new tariffs were rolling out, we had IEPO fentanyl duties, we had IEPO reciprocal duties, we had section two thirty two duties. There were a lot of changes taking place at that time, and we saw that ACE, seemed to remove some of the data validation mechanisms that were previously in place. And we were seeing entries be accepted with information that should not have been accepted and previously would not have been accepted, whether that was a third party filing software issue or a broker issue or misunderstanding of the new regulations, I would really encourage you all to audit these entries prior to submitting them to Kate. Ensure the HTS classifications are accurate, the countries of origin were declared correctly, valuation and the tariff sequencing was done appropriately. And especially if you have any two thirty two breakouts, ensure that those values were declared correctly because if you do need to correct any of these entries via PSC, you will need to do so prior to Kate submission. On that note, we had a little bit of back and forth and received a confirmation from CBP's IUPRA refund desk earlier this week that if you do have errors that you need to correct on an entry, you need to file the c, the PSC, let it be fully accepted and processed and then liquidated before uploading that entry to Kate. If you don't do so, it's possible that, the entry in CAPE will be processed and liquidated without the material changes included on the PSC because the CAPE process will move a little bit quicker. So be aware of that timeline. If you have entries that you need to correct, please do so before submitting those to CAPE. The next item here is to review the data to confirm CAPE eligibility. I would really discourage anybody from just taking, a report of all of their entries cleared over the last year and uploading it to cape without doing a review to ensure that those entries are actually eligible for a refund. Do a quick review, ensure that IEP duties were actually paid on that entry and that it's eligible for a refund. Also check the liquidation status. Currently in Cape Phase one, it is only unliquidated entries and entries that liquidated within the last eighty days that are eligible for refunds. Any entries that liquidated eighty one days or more, are not eligible in a current phase and will be included in future phases. Another validation to do here is just check to see if you have any entries that are included on open protests or entries that are flagged for reconciliation or included on open draw back claims. These entries will not be eligible for CAPE phase one, and so I would just put those in a bucket to include on a a later upload when we do receive more information about phase two, phase three, and what's included in those phases. And lastly, just avoid file validation errors. The CAPE submission template, to CSV document, it's pretty bare bones. It is really just the entry number included on a CSV document. That said, in the most recent CVP updates, Brandon Lord provided these three the top three file validation errors, showing that folks are uploading documents in the incorrect format. Entry numbers are in the incorrect format or they're the wrong length or they don't exist at all. Or there's importer of record or filer mismatches, meaning a customs broker attempted to upload entries into their organizational broker account, that were originally cleared by a different filing broker, and they're getting rejects for that reason. So do a little bit of work on, ahead of time, and you're saving yourself quite a bit of time downstream. Avoid errors and rejects where possible. And again, ensure that you are auditing these entries before proceeding with a CAEP submission. Lastly and very importantly, don't get scammed. There is a lot of money moving out to importers for these IAEPA refunds, and as such, they're opportunists and thieves and scammers looking to take advantage of the situation. Ensure you're only working with trusted partners. Remember that filing a cape declaration in ACE is the only way to obtain IAPA refunds. As you should always be doing, beware of phishing attempts, protect your personal information, don't click questionable links. And so the document on the right, we've seen quite a few of the importers that we've been working with receiving letters such as this. It includes their business name, their business address, and even some of their supplier information. And it's worth noting that this is all publicly available information, and these scammers are using this publicly available information to draft up letters to try to take advantage of the situation, and try to scam some money for these IUPRA refunds. Be aware of it. If you see any suspicious emails or requests, please report them to IUPRAfraud@cbp.dhs.gov, to make them aware of what's going on. And with that, I will turn it back over to mister Chapman to talk about what happens next.

Brian Chapman

Alright. Thanks, Callum. So now that you got your data prepped and you're all set up, ready to file your submission, and you get it uploaded to Kate, what happens? Well, you should get a message back from, within the portal in the claim status tab that shows how many were accepted and how many had errors. If you click on the hyperlink in the the claim number, it'll spit out a CSV that shows you exactly which ones were updated, and you'll get a a status message showing that your entry summary was updated. And, as Callum was saying earlier, these, entries now have the IEP tariffs removed from ACE. So, that's basically saying customs accepted it, and, you're good to go. If there's some on there with errors or failed messages, you might get one of these messages. And, it's not always clear exactly what's what's wrong with it. The error messages have gotten better, recently. They, oops. Sorry. They, the the first message, the ATS ATS relationship sequence mismatch is the one that we've had the hardest time figuring out. As a lot of times it doesn't feel like, there's an error at all when we when we review the entries. But, one example we can I can give is, there's a two thirty two exclusion added to the entry, and, no, two thirty two duties were applied? So, custom sees this, and they're like, well, you you excluded yourself from the IUPA duties, but you did not declare any two thirty two duties. So when, they went through and decided later, to refund that entry, they actually rate advanced it with a hundred percent two thirty two duties. So there's a lot of little things that, can cause, these errors. But there's usually, it's a specific broker that may have, you know, known that they had some software issues at the time. Maybe they had to manually calculate, the 15% European duties, or, they just had software issues at the time because CBP basically told the trade community, hey. You guys gotta calculate this correctly. We can't do it on our end. We can't tell you if it's wrong. The unable to calculate duty message, that was an early error message, but, it's no longer a message that we're getting. We saw it falsely, I think, flag a lot of entries. So if you happen to submit your cape upload in the first, week or two, I'd recommend maybe and you couldn't figure out what the error was, when you got that failed message. I'd recommend you try to reupload it into Kate to see if, it goes through because there's a chance that it was correct and it was just CBP's logic on the back end that didn't work correctly. The goods value amount must be reported on the chapter one to 97 line. So this happens a lot when, maybe you put a value on a two thirty two line or, a section three zero one line. And custom system just can't validate that the entry is correct because, based on their rules, they're not supposed to have a value on there. Goods value amount on an IUPUHTS line, pretty much the same thing, as the previous one. Entry summary and, like, final liquidation status, that's basically, it's past the eighty day deadline that they gave us for phase one, so you kinda have to wait till phase two for that. No IEPI HTS on an entry. Maybe you did use an exclusion and you never actually paid any IEPI. One common one they've they've pointed out in their CIT updates is, document formatting errors. So I guess people are using Excel file instead of a CSV, or maybe they're trying to upload a TXT file or something like that. But, that that one's pretty easily fixable. Overall, just make sure you review the error with your broker and make sure that, you can try to correct it with the PSC as Calum was saying earlier. And, once the PSC is accepted, then it should be able to go through, into Kate. So after your entries are accepted, what happens now? Well, they said refunds will be issued within sixty to ninety days from the acceptance date. However, we've actually seen the first refunds issued, a lot sooner, like within three to four weeks of the first submission. They're actually issuing refunds on every entry that was liquidated at the time of the cape upload. And what we kinda think is they've had their chance to review. They had three hundred and fourteen days to review for compliance. So CBP is basically saying, hey. Let's just give them their money back. We already had our chance to issue CF 20 eights, 20 nines, or, you know, reach out to them and ask questions. Let's just give them that money right now. During the meetings with the CIT and CBP, they did originally, ask for a forty five day compliance review after the submission. So I think what CBP is doing is they're kinda holding off on paying out any of the unliquidated entries, until they have their forty five days. So we're getting really close. Tomorrow is actually day 45 for, the first CAPE filings that were done on April 20. So, we still haven't seen, any requests for compliance reviews or, requests in general on, any CAPE claim from CBP. But, my guess is if there are some, we'll start seeing them soon because, that window is closing. So the biggest question everyone wants to know is when will the rest of them come? And we aren't sure. CBP hasn't really issued any guidance. But during their meetings with CIT, they did say they wanted to keep the the natural liquidation cycle, which we think means that they will refund them in lumps similar to how they refunded, the liquidated entries. But this would also make a lot of entries that filed at the end of twenty twenty five and early twenty twenty six outside of that sixty to ninety day window. So, it's really remains to be seen until we see some kind of pattern. But, my two guesses are either one, they'll follow the liquidation cycle, and maybe you'll get weekly batches based on every entry that liquidated that that week, or they'll give you some lump sums and just won't tell us anything. And we'll just be surprised when it hits your account, and you'll have to reconcile to make sure you got the right amount. Alright. So how can you monitor the refunds? As I kinda said earlier, it's it's been kind of all over the place. They've been issuing, the refunds every day of the week. Even Sundays, we've seen some clients get some refunds. But you can pull these four reports. These are all, available in your ACE reporting account. CBP built all of them, to help, you track things for that they're issuing. You can search in your, reports, section of the ACE just by the the, report name, so you might wanna take these down. Alright. So the ESO22. This one I find is the most helpful of all four. It gives you kind of a holistic overview of all the entries that were accepted into CAPE. So it'll show you each cape claim number and each entry that is on that cape claim number. It'll also show you, you know, if there's a forty eight eleven party, which I've highlighted in those first two boxes. If you have a forty eight eleven party, designated, that means the refund is gonna go to that party. So, anytime that populates, you'll you'll wanna make sure that once you see, refund information start populating in m through q, columns m through q, that you reach out to that party and make sure that, they keep you aware of, when they receive the refund so you can get them from them. Columns m through q are are usually blank until, they transmit it to the treasury, which is basically customs saying, yes. These entries are good to go. We're gonna send it to treasury, and they can issue the payment. So in the, columns m through k, you'll be able to see the duty amount that you should get back and the interest. The refund number, that's important for later. And, the refund date is not entirely accurate. We've seen anything from two to twelve days from that date. So, it's kind of a field I disregard. And also the refund status. The last column I wanna highlight is, if it says transmitted, that's good. That means the treasury is working on it or has sent it. If it says certified, you'll you'll want to run another report that I'll talk about later. But that means, it was likely rejected because you didn't have ACH refund set up. Alright. So the Rev six zero three trade report. This one will show you any refund coming your way, whether it's drawback, PSCs, or CAPE or protest. Any kind of refund that's being issued to your account will show up on this report. So, as you can see here, you can see that, there is a CAPE claim on the second line, and it has SAP ACH rejected. This is a critical message. If you see this, you'll need to put in some work to make sure your ACH refund tab is updated and also reach out to, the reissue, revenue refunds, email address, which, they'll they'll have to reissue your refund to once your account is set up, and it usually takes an extra four to six weeks. The rev six one three report ACH rejected. So if you see certified in the ESO 22 or you see SAP ACH rejected on your rev six zero three report, this is where you'll want to, double check and see how much, you could get back. You wanna reach out to the revenue refunds, email as soon as you have your ACH refund set up so they start to work on the reissuance. Don't worry. It's not that you won't get these funds. It just makes it take a lot longer, and causes you a few extra steps, and they will reissue it reissue it to you. And then the rev six one five report is all the details, about a specific cake claim. So if you remember earlier, I mentioned the refund ID. This is where you can actually use it. It's it's the only way you can actually run this report too, But I'm not exactly sure why they made this separately from the ES 22, but it's it's a nice tidy way to show you maybe your accounting team or your finance team, exactly what refunds they're getting and why, which entries they go to, which shipments, and, maybe break out the interest and, do the amounts for them so they can kind of reconcile on their end. And those are basically the ways you can track it. Hopefully hopefully, we see some more cadence soon on, exactly what we can, expect for the unliquidated entries, but, that remains to be seen. And for some CIT and CBP updates, I'm gonna pass it back to Calum to talk about all the, fun that's happened in the last week or so.

Calum Coulter

Thank you Brian. It is an exciting time to be working in a world of trade. Quite a few updates over the past couple of weeks and a couple of upcoming deadlines in the next few weeks as well. Let's dive into it. Can you keep some high level updates here? There's quite a bit going on, but let's see. One thing to be aware of is May 26, CBP quietly updated the IEPAA FAQ page to account for some open question questions about entries that are flagged for reconciliation. And according to that, CBP is working on a, phased solution to process unliquidated or liquidated entries flagged for reconciliation. They also included some suggestions about upload timing to CAPE, and stated that the suggestion is to hold reconciliation filings until after CAPE processing is complete, unless you're approaching a deadline in the next thirty days. So they're providing some suggestions here but it is worth noting that entries that are actually flagged for reconciliation are still not eligible for CAFE Phase one. What this says to me is that CBP is working on the mechanism to include these entries on a subsequent phase, and that these are likely to be included in the next, phase of CAEP eligibility. Okay. The following day on May 27, Judge Eaton with the CIT issued two orders. The first was asking CBP to come and explain why the CIT shouldn't remove the suspension to require all IEP duties to be immediately refunded, and demanded that briefs be submitted by all parties by June 4 which is tomorrow, and the second was requiring Commissioner Rodney Scott at CBP, to appear in person on June 9 and explain CBP CBP's policy, and when they're going to comply with the order to reliquidate and refund all entries with IEPAA duties. And so this is a little strange and, it's definitely an escalation from, Judge Eaton with the CIT. Historically, we've seen, executive director Brandon Lord with CBP giving the updates to Judge Eaton. And with this order, it looks like the judge is looking to move up the food chain and go all the way to the top to demand some answers from commissioner Scott. So this should be, interesting to see how this all plays out, and keep your eyes on that channel. Two days later, the government did file a motion responding to those two orders from CIT on the twenty seventh, really just requesting, that either Brandon Lord or Susan Thomas from CBP, who are both a little more operationally involved than Commissioner Scott, replaced the commissioner on that June 9 hearing, just because they'll have more direct knowledge, of the refund process and hopefully can answer his questions. The second part of that is that the government indicated, that they intended to appeal the universal injunction on the finally liquidated entries. There's an argument there that CBP has no authority to reliquidate entries and issue refunds, without an importer specific court order for finally liquidated entries. And as expected, yesterday evening, we saw that the government did issue that appeal. They submitted the appeal and arguing those two points. First, that CBP commissioner Scott, his testimony was unnecessary and unwarranted and should not be required, and the second was to seek a stay on the universal injunction on finally liquidated entries. So this was not unexpected, after reviewing the May 29 order, but is showing that things are moving pretty, pretty quickly here. That said, operationally, I do not see the appeal here impacting much of, the entries that that are included on Cape phase one. So if you have refunds that are already in motion, entries have been accepted in cape phase one, or you've already received those refunds, I do not expect there to be a terribly substantial impact from, this appeal, if at all. What this is really going to impact is entries that would be eligible for, CAPE phase two or the later phases and is really focused on finally liquidated entries. What that means here is any entry, that was liquidated more than ninety days in the past. That's where it is considered to be finally liquidated entry. It's still an appeal period, or a protest period that remains open between ninety and one hundred and eighty days post liquidation, but entries are considered to be finally liquidated after ninety days. Okay. And a couple upcoming deadlines to be aware of as well. As I mentioned before, June 4, the briefs are due in response to the May 27 order. June 8 was going to be the deadline for the government to appeal, but we have already seen them issue their appeal, so they're getting ahead of that deadline. June 9 is the hearing on those June 4 briefs. This is where Commissioner Scott was directed to appear to answer the questions on the anticipated timing and the policy of CPP in regards to these refunds. The following day, June 10 is the next progress update on CAPE from CPP. These are the regular updates that we've been receiving from Brandon Lord, showing how the CAPE process is going, how many injuries have been accepted, the volume of refunds being issued out to importers, etcetera, etcetera. So it's a good one to monitor as well. And then June 11, there will be a closed settlement conference before the court as well. So there's obviously a lot going on these days and things are changing day by day, but it's fascinating to stay on top of. And so keep your eye out for more updates coming up from the court. Keep your eye out for CSMS messages coming and we have another, tariff webinar coming up in a couple of weeks as well, so monitor this channel for future updates too. And with that, let's take a look at a couple of resources, and just cover a couple of ways that Flexport can help support you in these times. First off, we have a free AI tool that runs a compliance audit and your historical customs entries to surface any mistakes, misclassifications, missed duty savings. Go ahead and click on the button labeled audit your customs broker above your screen here to get started with that. We would also really encourage you to use the tariff refund calculator and check out the tariff simulator tool as well if you haven't already. Both fantastic tools and worth reviewing to get familiar with. Lastly, if you would like to get in contact with the Flexport team, you can email us at classificationflexport dot com for any classification or duty rate questions and email us at, customsbd@flexport.com, for any questions related to trade advisory, duty drawback, or brokerage inquiries as well. And with that, welcome back, mister Brian. Let's jump into some q and a.

Brian Chapman

Yeah. Thanks, Calum. Let me throw a forty eight eleven question at you. There's a couple here, but I'll kinda summarize both into one. Basically, they have an ACH setup, but they're not receiving a refund because their broker is. What can they do to change that? And, also, because my broker isn't notified. Okay. That's that's the question.

Calum Coulter

Okay. It's a good question, and it's one we've been receiving quite a bit the last couple of weeks. And so, for the forty eight eleven notify party, this allows another party to receive the IECO refunds on your behalf, but it's worth noting that the forty eight eleven, it requires a two part trigger. And so you have to have the forty eight eleven notify party on file in your ACE account, and the broker needs to have, declared the their, tax ID number in the 4811 field on each specific customs entry. And so if you're seeing that your broker is receiving refunds on your behalf and you do not want them to, then I would encourage you to contact your assigned center at the c, to have them revoke the forty eight eleven notify party, in your ACE account. And that should cover it for all future entries. As far as entries that have already been processed and are in the queue for refunds, I would take that question to them for how to handle that if your broker's receiving your refunds without your authorization. I would definitely highlight that to them. It's a good question.

Brian Chapman

Awesome.

Calum Coulter

Okay. Let's see what else we got here. Okay, Brian. I got a couple for you. Let's see. So first, what's the status of the entries that have already been liquidated? Is there an update on how those will be handled by Kate? I know you addressed this a little bit, but you wanna elaborate?

Brian Chapman

Yeah. So the ones that are finally liquidated, we still haven't gotten any clear guidance on what to do with them. Currently, you can file a suit with the CIT, or you can file a protest, to protect your rights to those refunds. Neither might might be necessary depending on what happens with the appeals, but that's kind of a TBD right now. But those are the two recommended, actions that you can take right now. Alright. Let's look for one for you, Calum. Appeal question. Let's see. Sorry. I'm not, seeing one that we didn't answer already. If a broker files an entry in their own name, can the broker receive the refunds? I would say yes. I think that's a if if they're the importer of record sorry. I was asking you, Calum, but then I was I was questioning it in my my own head. If the broker files it as the IOR, they should be the one receiving the refunds because all the refunds are going to the importer of record.

Calum Coulter

I would agree with that. Yep. If if that's what you mean by filed it in their own name, if they're set up as the importer of record, then they would be the ones receiving refunds. That's correct.

Brian Chapman

agree. Let me oh, go ahead.

Calum Coulter

Oh, yeah. I got one for you about timing. I know this is a question we've been getting quite a bit these days. So we've received refunds on entries liquidated before April 24, but nothing after that date. Is that what you're seeing as well?

Brian Chapman

Yes. Yes. So it's pretty much the only refunds that we've seen come through, are just the liquidated entries at the time of the cape filing. So say you file it today, anything that was within eighty days of that liquidation, will will probably be refunded first. We've seen it, like, in two tranches sometimes, which doesn't really make sense that they'd refund, you know, seven of the entries and then two of them later. But, again, they haven't really provided any guidance to what they're doing, so, that's totally normal.

Calum Coulter

Right.

Brian Chapman

Let me find one for you. Some some of my entries came back failed. Oh, wait. Sorry. If my container arrived in The US on 06/2425, is it already too late to file, or is it included in phase one?

Calum Coulter

That's fair question. Arrival date is relevant, but really what would hinge this would be hinging on is the liquidation date of the entry. So if this was cleared around June '25, it could be eligible for phase one, unless this was liquidated sooner than expected. We typically see entries the regular liquidation schedule is three hundred and fourteen days after entry. And then again for cape phase one eligibility, this also includes entries that liquidated between zero and eighty days in the past. This entry would likely be included in Cape Phase one, but really you should check the liquidation date of that. If you don't have that handy, check with your customs broker and they should be able to tell you pretty quickly. Okay,

Brian Chapman

Awesome.

Calum Coulter

Brian. I got one for you. So does the e s 003 report from Ace show only IEPRA related entries, or are there other entries without IEPRA claims included as well?

Brian Chapman

Yeah. So the ES003 is a general report, so it'll show everything. So you can you'd have to filter out which ones did have which IUPA HTS numbers, you did pay duties on. There's no need to include the exclusion ones. So, like, if you used an in transit exclusion, you didn't pay IUPO on it. So it's not, not something you really need to request, a refund on. So, yes, you you, you do need to filter down once you do have that, D S zero zero three. So question for Calum. When can we expect CBP to open up eligibilities for entries flagged for reconciliation?

Calum Coulter

It's a good question, and we are definitely asking the same. I don't have a good idea of when they will be opening that up. Based on what we're seeing in the CBP FAQ page, which I would also encourage you all to get familiar with and follow along for updates, it looks like there are things in motion with entries flagged for reconciliation, but they have not published any concrete date when these will become eligible for upload into the Calum portal. It's a big question, and there are quite a few folks who have been pushing CVP to acknowledge this. And so this is the first real acknowledgment of, there being movement in regards to reconciliation filings and entries flagged for reconciliation. So it's certainly something they're working on, but, unfortunately, we just don't have a concrete date provided to us yet. Team monitoring for CSMS messages as well. They did indicate in the quiet, notes included in the FAQ that, additional updates will be distributed via CSMS messages. So sign up for those notifications as well if you haven't already. There's really good information, and you'll be the first to hear.

Brian Chapman

Yes. Always monitor the CSMS. Alright.

Calum Coulter

Okay, Brian. I got another one for you. So if refund gets sent back to sender due to banking account issues, do you have to resubmit?

Brian Chapman

You do not have to resubmit your Calum claim, but you do have to, basically make sure your ACH refund tab is set up correctly. There's an email on that was in the slideshow that you can you can download, to reach out to, the refund team to retrigger it, once you have it set up. And then, they'll confirm that they got your message and that you should receive it in four to six weeks. Alright. Let me get one for you, Calum. So where do you file the 48 elevens?

Calum Coulter

Okay. This depends a little bit if you're an importer or a customs broker. I'm not sure who's asking the question, but I can touch on both. If you're an importer of record, you will need to submit the forty eight eleven information in the notify party section of your ACE importer account. Just populate it there and it'll reflect pretty much immediately. If on the other hand, you're a customs broker and you want to include the 4811 information on, your entry, I believe in 2026 version of the 70 501, I think it's Box 28 now. It used to be Box 24, I believe. And you'll include that on, on the entry. Every entry you file, you should do want to reroute those refunds for.

Brian Chapman

Awesome. We might have time for one more if, you wanna throw one more at me. Looks like we're. just getting. time.

Calum Coulter

Okay. Alright. I got one for you. So do the CAPE refund ACE reports tell you the refund and interest per individual entry, or any lump refund received will have to be routed internally, to different projects accordingly. I think it's really about reconciling refunds at the entry level. Which ACE report can you use to identify what amounts are being received for which entries?

Brian Chapman

Got it. Got it. Yeah. So the the e s 22 definitely shows you a breakout. There's a column for the refunded duty and a due column for the refunded interest per entry. So you can, match that up to, whatever you're seeing on your on your report that you pulled before, you did the cape upload. Also, there's, a refund ID. So each refund ID corresponds to the remittance. So if you there's three refund IDs, those will be three separate ACH, transactions that customs sends you. So you can kinda group it to make sure that each one, you receive the correct amount. We have seen some that, are actually a little different, and, I would recommend reaching out immediately to the refunds email just to see why there's a discrepancy between the two numbers because, only CBP can really explain that one. But, thank you everybody for joining us. This concludes today's webinar. We'll email everyone a link and, to the recording tomorrow morning. Thank you again for joining us, and have a great day.