Why 28,000 CAPE Filings Got Rejected in the First Week — and How to Fix Yours

Of the 75,306 CAPE refund declarations filed in the first six days of the new IEEPA refund portal, 27,991 (37%) were rejected at initial file validation. The pattern is consistent: brokers who rushed in without clean entry data hit cascading rejection errors. Here's what's failing — and how to make sure your CAPE filings pass on the first attempt.

The Five Rejection Patterns Driving 27,991 Failed Submissions

Across CBP's CSMS #68340863 update, Baker Tilly's portal monitoring, and practitioner reports from the first week, five rejection patterns account for the vast majority of failed CAPE submissions.

1. Duplicate Tax-ID Errors (most common)

The single largest rejection bucket. Multiple declarations referencing the same Importer of Record (IOR) tax ID are landing on top of overlapping entry summaries — for example, two brokers filing on behalf of the same client, or one broker submitting two declarations that both claim a shared subset of entries.

Fix. Designate a single broker of record per client for CAPE filings before you submit. Run a pre-flight dedup query against your ABI-side entry summary table grouped by IOR and entry number. If multiple brokers have historically filed for one client, decide which broker owns the CAPE filing and document that assignment in writing.

2. Mismatched IOR / Consignee Fields

CAPE validation requires that the IOR and consignee fields on the declaration exactly match the ACE entry summary record. Brokers who pulled entry data from in-house systems rather than directly from ACE are seeing field-level mismatches — typically transposed CBP-assigned numbers, outdated IOR addresses, or consignee names that have been updated in ACE but not in the broker's CRM.

Fix. Pull entry summary data direct from ACE for every CAPE declaration. Re-validate the IOR EIN against IRS records before submission. Do not source IOR/consignee fields from internal CRMs or accounting systems.

3. Portal Congestion in the First 72 Hours

Not strictly a data error, but it produced thousands of timeouts that CBP logged as rejections. The April 20-22 window saw sustained ACE login pressure (a 70% spike on Day 1) and the CAPE submission queue intermittently returned timeout codes that brokers' middleware interpreted as hard rejections.

Fix. Resubmit any declaration that came back with a timeout-class error code — these are not substantive rejections. Schedule large batch submissions for off-peak windows (overnight ET) until CBP confirms the queue has stabilized.

4. Wrong Liquidation Status Flagging

Phase 1 covers only unliquidated entries and entries liquidated within the last 80 days (which preserves the 90-day voluntary reliquidation window under 19 U.S.C. 1501). Declarations that flag finally-liquidated entries (90+ days) as Phase 1 eligible are auto-rejecting. Some brokers built filing logic against draft eligibility criteria from earlier CBP guidance and never updated when the final criteria locked in.

Fix. Pull current liquidation status from ACE for every entry on the morning of submission — not from cached data. Build a hard eligibility filter into your filing workflow that excludes any entry liquidated more than 80 days prior. Phase 2 (covering final-liquidation entries) is targeted for Q3 2026; route those entries to a hold queue rather than forcing them through Phase 1.

5. Missing Supporting Documentation

CAPE declarations require entry summary references and payment confirmations attached or referenced via ABI. Submissions that arrive without payment trail documentation are flagging for compliance review and, in many cases, rejecting outright. CBP's update bulletin specifically calls out missing duty payment confirmations as a recurring issue.

Fix. Build a documentation packet per declaration that includes the entry summary number, IEEPA duty amount paid, payment confirmation (ACH or check reference), and date paid. Attach via your ABI broker software's document upload path or reference the documents in the declaration narrative field.

How to Build a Clean Filing Package Before You Submit

A pre-flight checklist that catches most rejections:

• IOR EIN re-validated against IRS records this week
• Liquidation status pulled from ACE on the morning of submission
• Entry list deduped against any other broker filing for the same IOR
• IEEPA duty amount verified against the original entry summary
• Payment confirmation documented (ACH/check reference + date)
• Consignee fields pulled from ACE, not CRM
• Submissions over 100 declarations scheduled off-peak

Brokers running this checklist in week two are reporting first-pass acceptance rates above 85% — well above the 63% network-wide average from the first six days.

Resubmitting After Rejection

There is no penalty for rejected CAPE declarations and no limit on resubmissions. CBP's CSMS #68340863 explicitly confirms that failed validation does not consume eligibility, does not flag the IOR for compliance review, and does not affect the 60-90 day refund timeline once a clean declaration is accepted.

That said, every resubmission costs you queue position. The 27,991 declarations rejected in week one are now competing with new declarations for processing capacity, which is part of why the network-level acceptance throughput slowed mid-week. File once, file clean.

Why Brokers With ABI Hygiene Are Filing Faster

Brokers reporting near-zero rejection rates share three operational traits, all of which predate CAPE: direct-to-ACE data pulls (no CRM caching of IOR or consignee fields), daily liquidation status sync, and designated broker-of-record agreements that eliminate overlap with other brokers.

If your operation hasn't enforced these basics, CAPE is the forcing function. The brokers who clean up ABI hygiene now will move faster on Phase 2 (final-liquidation entries) when it opens in Q3 2026 — and the eligible-entry population in Phase 2 is older and messier than Phase 1.

For the broader Phase 1 launch numbers and what's coming next, see CAPE Phase 1 Is Live: 75,306 Refund Claims Filed in the First Six Days. For the underlying CBP guidance documents brokers should have on file, see CBP Issues Two Post-Launch CSMS Updates on CAPE.

Sources

Baker Tilly: IEEPA Refund CAPE Portal — Processing Signals, Timing and CBP Review Risks | Perkins Coie: Launch of CAPE Phase 1 — Essential Guidance | CSMS #68340863 — CAPE Update | Norton Rose Fulbright: CBP Issues Tariff Refund Instructions

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