CBP Issues Two Post-Launch CSMS Updates on CAPE: What Brokers Need to Read Today
Within days of the CAPE Phase 1 launch on April 20, 2026, U.S. Customs and Border Protection issued CSMS #68315804 (introduction) and CSMS #68340863 (update) — official guidance documents that every customs broker handling IEEPA refund filings should have on file. Here's a plain-English walkthrough of what each bulletin covers and what it means for your daily workflow.
Why CSMS Bulletins Matter
Cargo Systems Messaging Service (CSMS) bulletins are CBP's official channel for trade community guidance. They carry the same operational weight as a Federal Register notice for ABI filers — when CBP changes a process, a CSMS goes out. Brokers who don't subscribe to GovDelivery for CSMS updates routinely miss filing requirement changes that take effect within days. For CAPE, two bulletins have shipped in the first week, and a third is expected before Phase 2.
CSMS #68315804 — CAPE Introduction
Issued with the April 20 launch, this is the foundational bulletin. It defines what CAPE is, who can file, and how submissions flow through ABI.
What it covers:
- Phase 1 scope. Entries that are (a) unliquidated, or (b) liquidated within the prior 80 days. The 80-day window preserves the 90-day voluntary reliquidation period under 19 U.S.C. 1501 with a 10-day filing buffer.
- Eligibility. IEEPA-paid duties only. Section 232, Section 301, and AD/CVD are out of scope and should not appear on a CAPE declaration.
- ABI submission. New declaration type code over existing ABI connections. Required fields include IOR, entry number, entry summary line references, IEEPA duty amount paid, payment confirmation, and current liquidation status.
- Refund timing. 60-90 days following acceptance, absent compliance review.
What it means. Map every active IEEPA-tagged entry summary against the Phase 1 criteria today. Build a pre-submission filter that excludes anything liquidated more than 80 days ago and route those entries to a Phase 2 hold queue.
CSMS #68340863 — CAPE Update
Issued mid-week after the launch, this bulletin addresses the issues CBP saw in the first wave of submissions. It is the more operationally important of the two for brokers actively filing.
What it covers:
- Acknowledgment of first-week rejection patterns. CBP confirms the 37% rejection rate at initial validation and identifies five recurring causes: duplicate IOR submissions, mismatched IOR/consignee fields, portal congestion timeouts, wrong liquidation status flagging, and missing payment documentation.
- Resubmission guidance. Failed validation does not consume eligibility, does not flag the IOR for compliance review, and does not affect the 60-90 day refund clock once a clean declaration is accepted. There is no penalty and no resubmission limit.
- Recommendations for clean submissions. Pull liquidation status fresh from ACE on submission day; designate a single broker of record per importer for CAPE; attach payment confirmation documentation; schedule large batch submissions for off-peak windows.
- Compliance review triggers. Declarations claiming refunds above $5 million per entry, declarations from IORs with a prior compliance flag, or declarations missing payment documentation are automatically routed to compliance review, which can extend the refund timeline beyond 90 days.
What it means for your workflow. This bulletin is effectively the CBP-endorsed checklist for clean filings. Treat its recommendations as filing requirements, not suggestions. For the full breakdown of rejection patterns and remediation steps, see Why 28,000 CAPE Filings Got Rejected in the First Week.
The Phase 1 Eligibility Checklist as CBP Defines It
Pulling directly from the bulletin language:
| Entry Status | Phase 1 Eligible? |
|---|---|
| Unliquidated entries with IEEPA duties paid | Yes |
| Entries liquidated within 80 days of submission | Yes |
| Entries liquidated 81+ days prior | No — Phase 2 |
| Section 232 duties paid (no IEEPA component) | No — out of scope |
| Section 301 duties paid (no IEEPA component) | No — out of scope |
| AD/CVD duties paid | No — out of scope |
| IEEPA duties on entries already refunded via protest | No — duplicate claim |
ACE Submission Requirements
Every CAPE declaration must include, per CSMS #68315804: IOR number, CBP-formatted entry number, entry summary line references for every line claiming IEEPA refund, IEEPA duty amount per line, payment confirmation reference and date, current liquidation status, and consignee name/address exactly matching the ACE entry summary record.
Common First-Week Issues CBP Is Tracking
CSMS #68340863 names five issues driving the bulk of week-one rejections, in rough order of frequency: duplicate tax-ID submissions across overlapping entry sets, mismatched IOR/consignee fields, portal timeouts during peak windows (logged as rejections), Phase 1 claims on finally-liquidated entries, and missing duty payment confirmations. CBP's framing matters: these are characterized as data hygiene issues, not bad-faith filings. The bulletin provides a remediation path, not enforcement consequences.
What Brokers Should Communicate to Clients This Week
Three messages every broker should push to importer clients: status of their CAPE filings (submitted, accepted, or queued for resubmission), expected refund timing (project the 60-90 day window forward — mid-June through late July for Day 1 filings), and Phase 2 outlook for clients with finally-liquidated IEEPA entries (targeted Q3 2026).
For the launch-week numbers driving these conversations, see CAPE Phase 1 Is Live: 75,306 Refund Claims Filed in the First Six Days.
Where to Find the Bulletins
To subscribe to CSMS bulletins via GovDelivery, visit the CBP CSMS subscription page and select the "Trade" topic group. You'll get every CAPE-related bulletin in your inbox the moment CBP publishes it. Brokers who file IEEPA refund declarations and don't subscribe are filing blind.
Sources
CSMS #68315804 — CAPE Introduction | CSMS #68340863 — CAPE Update | CBP CAPE Phase 1 Trade Information Notice (PDF) | CBP IEEPA Duty Refunds Page
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