Fraud notice: CBP has warned about fake IEEPA refund solicitations. CAPE Factory never files for you, never touches ACE credentials, and parses everything locally in your browser.
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For U.S. licensed customs brokers · Early access open

The CAPE CSV is free.
The triage is the product.

CBP wants a list of entry numbers — 9,999 per declaration, nothing else. Generating that file is worth nothing. What nobody has built is the layer underneath: splitting a broker's entire book of importers into four buckets, because two of them cannot go through CAPE as-is, and one of them is running out of time.

$166B
IEEPA duties collected
75,000+
CAPE declarations filed
$1.6B
Refunds undeliverable — bad ACH data
—
Days to Feb 4, 2027
first fentanyl deadline
Run the triage engine (free) Check my deadline

Refunds are not automatic — CBP is not scanning its own records. And the earliest entries time out on February 4, 2027.

The core insight

Four buckets, not one CSV

Every tool on the market stops at "here's your declaration file." That's the part CBP made trivial. Most of them also stop at two outcomes. The real decision tree has four — and the middle one is where brokers lose money without knowing it.

A · CAPE

Unliquidated, or liquidated within 80 days

  • Route: CAPE Phase 1–2
  • Timeline: acceptance ~10 days, refund ~60–90 days
  • Watch: unliquidated entries liquidate ~45 days after acceptance
The easy money. Also the only bucket the existing tools touch.
P · Protest window

Liquidated 81–180 days ago

  • Route: protest under 19 U.S.C. § 1514, within 180 days of liquidation
  • Trap: CBP does not process CAPE claims on protested entries
  • Decision: protest, or wait — never both blindly
Almost nobody splits this out. Lumping it into "CAPE" gets the declaration rejected; lumping it into "litigation" burns a $400 filing fee that wasn't needed yet.
B · Litigation

Finally liquidated — past 180 days

  • Route: §1581(i) action at the CIT, $400 filing fee
  • Then: CAPE Phase 3 — opened Oct 6, 2026, but only for plaintiffs holding a court-ordered reliquidation
  • Clock: two years from accrual (28 U.S.C. § 2636)
You must sue first, then file. If you don't flag this bucket, the client is never told the option exists until the clock runs out.
C · Expiring

Deadline inside 180 days

  • Confirmed anchors: Feb 4, 2027 (fentanyl) · Apr 5, 2027 (reciprocal)
  • Rolling: every later deposit runs two years from its own date
  • Use: the sharpest line in the sales conversation
"Your client's February 2025 entries time out on February 4, 2027." That sentence closes brokers faster than any feature list.
Hard exclusions — these get a declaration kicked back

Section 301 and Section 232 lines are not IEEPA and are not refundable here. Add reconciliation-flagged entries, drawback claims, AD/CVD, warehouse entries (type 21 / 22), and anything with an open protest. A naive CSV dump includes them and the whole file gets rejected.

Pre-flight

The five things that silently kill a refund

None of these are classification problems. They are operational misses — and $1.6 billion of certified refunds are sitting undelivered right now because of number one.

  1. 1

    ACH refund enrollment

    Since February 6, 2026 refunds are electronic only. No valid ACH details on file in ACE means the refund is rejected outright — not delayed, rejected. This is the entire explanation for the $1.6B undelivered as of July 31, 2026.

  2. 2

    Do not file a PSC

    CBP has said explicitly that Post Summary Corrections should not be filed for unliquidated IEEPA entries. CAPE is the administrative route; filing the wrong instrument slows you down instead of speeding you up.

  3. 3

    Who actually gets paid

    Payment goes to the importer of record. Where another party bore the duty, Form 4811 redirects the payment — and it must be in place before the declaration is filed.

  4. 4

    Open protests block CAPE

    Entries with a pending protest are not being processed through CAPE. Decide deliberately: protest under §1514 within 180 days of liquidation, or leave the entry clean for CAPE — not both by accident.

  5. 5

    The two-year clock

    Residual-jurisdiction actions at the CIT run two years from accrual, and practitioners date accrual to the duty deposit. Earliest anchors: February 4, 2027 and April 5, 2027.

Who we sell to

Your customer is not the importer. It's the broker.

CBP said it plainly in the Federal Register notice. Read the operative sentence:

"Most small businesses do not have an ACE account and instead enlist the assistance of a licensed customs broker… They will continue to be able, and are expected, to use their customs brokers for the IEEPA refunds process and CAPE." — CBP, Federal Register

Small and mid-size importers cannot self-serve. Every one of them flows through a licensed broker — and a broker carries dozens to hundreds of IORs, each needing its own declaration file and its own liquidation clock. Only the IOR, or the broker who filed the entry, can submit. A freight forwarder cannot.

That's not a consumer app. That's a B2B2B batch processing business, and the buying unit is the brokerage desk.

What this means in practice

1 broker50–300 IORs
1 IOR1 declaration file
1 filemax 9,999 entry numbers
Every IOR4 buckets to track
Every entry2 clocks (protest + §1581(i))

Multiply that by a few hundred clients and the manual version is a spreadsheet nobody has time to maintain — which is exactly why it isn't being done.

Free · no email required

When does the clock run out?

Enter the date of the first IEEPA duty deposit for an IOR. Two years from accrual is the residual-jurisdiction deadline at the CIT. This is the page brokers forward to clients.

Basis: two years from accrual (28 U.S.C. § 2636), accrual dated to the duty deposit. Interest at CBP's published quarterly overpayment rate — Q4 2026: 7% non-corporate, 6% corporate (91 FR 60141). Rates change quarterly; always verify against current CBP guidance.

Fill in a date to see the window.
Try it now · runs in your browser

The triage engine

Paste entry data or load a sample. The engine strips non-IEEPA lines, splits the rest into buckets, applies both clocks, computes statutory interest, and exports the CAPE declaration, the protest packet and the litigation packet. Nothing is uploaded — parsing happens on this page.

Columns: entry_no, hts, liquidated, liquidation_date, duty_usd + optional entry_date, origin

Demo engine. Classification follows published CBP phase rules and statutory clocks, but it is not legal advice and does not see your ACE record. The production engine ingests ACE ES-003 exports directly and applies current CBP exclusion logic.

Build scope

Everything in the first two weeks

No roadmap theatre. This is the shippable surface.

Ingest

  • ACE ES-003 Excel export
  • Multiple IORs in one file
  • Hundreds of thousands of rows

Classify

  • Chapter 99 9903.01 / 9903.02 detection
  • Strip 301 / 232 — not refundable
  • 80-day CAPE, 180-day protest, §1581(i) two-year clocks

Export

  • CAPE declaration CSV, auto-split at 9,999
  • Protest packet with §1514 dates
  • Litigation packet + expiring-soon alerts

Validate

  • Open protests, reconciliation, drawback
  • AD/CVD · warehouse entries 21 / 22
  • Collection-window and USMCA origin flags

Acquire

  • Free deadline calculator
  • Open-source Excel triage template
  • Zero-competition long-tail SEO

Deliberately not built

  • No filing on your behalf
  • No ACE credential handling
  • No outcome guarantees
Pricing

Priced against what a broker bills, not against the refund

Primary

Broker

$499/month
  • Unlimited IORs
  • All four buckets + both clocks
  • CAPE / protest / litigation / expiry exports
  • Exclusion and pre-flight validation
  • Per-entry volume tier: $0.10–0.25

Brokers bill this to clients as a line item. At these numbers it is margin, not cost.

Get early access

Self-serve

$199one-time
  • For importers under 500 entries
  • Triage report + deadline map
  • Execution handed to their broker

Positioned as the client-facing entry point, not the main business.

Join waitlist

No contingency fees. Ever.

Charging a percentage of the refund crosses into unauthorized practice of law, and the money lands 60–90+ days later — you'd be chasing it forever. Flat software pricing keeps this a data-preparation product and keeps the broker's client relationship intact.

Risk & trust

We are a data-preparation layer. That's a feature, not a hedge.

We never file for you

CAPE Factory produces files and reports. Your desk, or your client's counsel, does the filing. No attorney-client interference, no UPL exposure.

We never touch ACE

No credentials, no portal automation. Files are parsed in your browser and never leave your machine.

CBP has warned about scams

Fake emails and social posts are already phishing businesses for IEEPA refund details. Trust is the whole game — so the disclaimer is hard-coded into the UI, not buried in a footer.

Policy can still move

The government's appeal on universal relief is pending at the Federal Circuit, and Phase 3 remains limited to plaintiffs with a court-ordered reliquidation. The product is positioned so a rule change costs a feature, not the company.

The window does close

Past mid-2027 this specific demand fades. Either harvest in three months, or pivot the same engine into evergreen duty-variance auditing — the durable version of this business.

No outcome promises

No guarantee of refund amount, timing, or eligibility. Every screen says so.

Early access

Get the triage engine before the February crunch

We're onboarding brokerages in batches. Tell us your IOR count and we'll size it with you.

FAQ

What brokers actually ask

Isn't this just a CSV generator?

CBP accepts a bare list of entry numbers, 9,999 per file. Generating it is a spreadsheet formula. The value is deciding which entries belong in it: unliquidated and recently-liquidated go in; entries inside the 180-day protest window need a different call; finally-liquidated entries need a §1581(i) action; and 301, 232, drawback, AD/CVD, warehouse and protested entries must be pulled out or the filing is rejected. Sorting is the product.

Why sell to brokers instead of importers?

CBP's own notice states that most small businesses lack an ACE account and are expected to use their licensed customs broker for the IEEPA refund process and CAPE. Only the importer of record or the broker who filed the entry can submit — a freight forwarder cannot. One brokerage represents dozens to hundreds of importers, so the blast radius per sale is far larger.

What changed on October 6, 2026?

CAPE Phase 3 opened for finally liquidated entries — but only for plaintiffs who already hold a court-ordered reliquidation. That means a §1581(i) filing has to come first. Also note: CBP is not processing CAPE claims on entries with an open protest.

What interest rate do you use?

CBP's published quarterly IRS-derived rate under 19 U.S.C. § 1505(c). As of the quarter beginning October 1, 2026 (91 FR 60141): 7% for non-corporate overpayments, 6% for corporate overpayments. Rates change quarterly and the engine lets you pick which basis applies.

Do you guarantee the refund?

No, and no one legitimately can. The government's appeal on universal relief is unresolved and CBP guidance is still moving. We prepare and structure data; you and your client's counsel decide and file.

Is my data uploaded anywhere?

Not in the demo — it parses in this page. Production runs browser-first with local parsing as the default, because CBP has already warned about phishing campaigns impersonating refund services.

How do you get the first hundred customers?

Reddit (r/ImportExport, r/customsbroker, r/supplychain, r/logistics) with an open-source triage template rather than an ad; LinkedIn outreach to customs brokers and trade-compliance managers using CBP's public licensed-broker roster; NCBFAA and regional affiliate chapters; and long-tail SEO on brand-new queries like "CAPE declaration CSV" and "how to file CAPE declaration" that have almost no competing pages yet.