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

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& 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 we will also cover the latest section 232 and 301 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 on your 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. Um hello Callum. And today's agenda, we're um kicking things off with what you do prior to submitting your CAPE submission. Um then we'll kind of 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& A. And jumping right in, I'm going to pass it to Callum. — Thank you, Brian. So, we've got quite a bit to discuss today. So, let's go ahead and get started. Uh, first section here, we're going to talk about what to do before you proceed with a Cape submission. Uh, 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. uh you're going to have to get your ACE account set up. Uh if you don't already have an ACE account set up, please begin getting that established right away. Uh the CAPE submission portal all sits within your ACE account. Uh so you absolutely will need an ACE account on file uh in order to receive the IPA refunds. Uh if you don't already have an ACE account set up, uh try to begin getting that established right away. uh with the refunds moving with the Cape process these days. Uh it seems like there's quite a bit of requests going through to CBP to get these accounts established. Uh last we were hearing it was taking roughly 2 to 3 weeks to get these uh ACE accounts set up. So if you don't already have that on file, uh go ahead and get started right away. Uh on the other side of that, if you are having ACE account issues, uh 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, uh go ahead and reach out to the ACE support desk. Uh there's an email and a phone number listed on the screen. Uh give them a call, send them an email, and they should be able to help you out. uh much like establishing the ACE accounts initially, uh they're receiving quite a few requests these days with all of the movement with AIPA duties and refunds moving through CAPE. Uh so we what we've been hearing from importers is that some folks are having a little trouble getting a hold of somebody uh during regular business hours or in the middle of the day. Uh so again, the support desk is monitored 24 hours a day. Uh so if you're not able to get a hold of anybody uh and you're sitting on the west coast, I would really encourage you to uh give them a call after hours or in uh off- peak hours and you will likely have some more success getting a hold of somebody. Something else we've been hearing from importers uh is that you can elect to receive a call back and again the support desk is monitored 24 hours a day and they're working even if you are not. So, 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. Uh, it's just something to be aware of. Okay. Second absolute mustd do here uh is check the AC refund authorization tab in the ACE account. Ensure that this is fully set up and the information is accurate. Uh, if you do not have your AC refund authorization tab set up in ACE, you will not be receiving refunds. uh CBP is not going to send you a check if you don't have that information filled out. Uh the refund will be rejected and will be stalled until you get that information set up. Uh so please before you proceed with a CAPE submission, uh ensure that the AC bank account information is on file uh and that you're fully set up there. uh if for some reason you uh missed that on the first round and you submitted Cape, it was accepted and a refund was issued uh that refund would be rejected and in order to get that resolved, you'll need to get the information set up in ACE uh and then request for the uh refund to be recriggered. Uh last we heard it was taken about four to six weeks to have the refunds reissued from uh once the original refund was rejected. Uh so try to avoid that if at all possible and ensure that all this information. Okay, with that you have your ACE account set up. Uh you're fully established. Couple things you're really going to want to do before you proceed with a cape declaration uh is really just data validation. Uh so first you need to download your data from a so that you can review it. Uh there are a couple of pre-built reports that are very helpful. The 003 is a good line level report that has quite a bit of good information in there. Uh that said, I would really encourage all of you to utilize the ACE customizable reports. Uh you can build these out to include whatever data elements you feel are relevant for your specific circumstances. Uh it takes a little bit of time to get used to the portal and get the reports built up from scratch. uh 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. Uh so would really encourage you all to do so. Uh next item very important once you get these ACE reports built up uh please save copies of these offline and ensure that these reports give you the ability to identify expected refunds. Uh Flexwork does have a good tariff refund uh calculator tool that I would encourage you all to use as well. Uh 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 IPA HTS codes are being removed from the ACE reports. So, if you don't have a good idea of what your expected IPO 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 the refund amounts you should be expecting will be. Uh, and it'll be quite a bit more difficult to reconcile the refunds you're receiving uh once those funds do start moving in your direction. So again, uh set up some reports, download them, save them offline, ensure you have the good, uh the relevant visibility before proceeding. Next item here is to go ahead and do a full audit of your entries to ensure accur accuracy and maximize refunds. Uh if we're thinking back to early 2025 when all of the new tariffs were rolling out, uh we had IPA fentanyl duties, we had IPA reciprocal duties, we had section 232 duties. There were a lot of changes taking place at that time and we saw that ACE uh 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. Uh whether that was a third party filing software issue or a broker issue or a misunderstanding of the new regulations. Uh I would really encourage you all to audit these entries prior to submitting them to CAPE. Ensure the HTS classifications are accurate, the countries of origin were declared correctly, uh valuation and the tariff sequencing was done appropriately and especially if you have any 232 breakouts, uh ensure that those values were declared correctly because if you do need to correct any of these entries via a PSC, you will need to do so prior to cape submission. On that note, we had a little bit of back and forth and received a confirmation from CBP's IPA 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 Cape. uh if you don't do so, it's possible that uh 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. Uh so be aware of that timeline. Uh if you have entries that you need to correct, please do so before submitting those to CAPE. Uh the next item here is to review the data to confirm CAPE eligibility. I would really discourage anybody from just taking uh 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. Uh do a quick review, ensure that IEP duties were actually paid on that entry and that it's eligible for a refund. Uh also check the liquidation status. Uh currently in Cape Phase 1, it is only unlquidated entries and entries that liquidated within the last 80 days that are eligible for refunds. Uh any entries that liquidated 81 days or more are not eligible in a current phase and will be included in future phases. Uh 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 drawback claims. uh these entries will not be uh eligible for cape phase one and so I would just put those in a bucket to include on a later upload when we do receive more information about phase 2 phase three and what's included in those phases. And lastly, uh just avoid file validation errors. Uh the CAPE submission template uh it's a CSV document. It's pretty bare bones. It is really just the entry number included on a CSV document. Uh that said, in the most recent CBP updates, uh Brandon Lord provided these three, the top three file validation errors, uh 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, uh or there's importer of record or filer mismatches, meaning a customs broker attempted to upload entries into their organizational broker account uh that were originally cleared by a different filing broker and they're and rejects for that reason. Uh so do a little bit of work on uh ahead of time and you're saving yourself quite a bit of time downstream. Uh avoid errors and rejects where possible. Uh and again ensure that you are auditing these entries before proceeding with a Cape submission. Lastly, and very importantly, uh don't get scammed. Uh there is a lot of money moving out to importers for these AIA refunds. Uh and as such there are opportunists and thieves and scammers looking to take advantage of the situation. Uh ensure you're only working with trusted partners. Uh remember that filing a cape declaration in ACE is the only way to obtain AIA refunds. Uh as you should always be doing. Uh be aware of fishing attempts. Protect your personal information. Don't click questionable links. Uh 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. Uh 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 uh and try to scam some money for these IPA refunds. Be aware of it. Uh if you see any suspicious emails or requests, please report them to fraud@cbp. dhs. gov uh to make them aware of what's going on. And with that, I will turn it back over to Mr. Chapman to talk about what happens next. — All right. 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 um within the portal in the claim status tab that shows how many were accepted and how many had errors. Um if you click on the hyperlink in the claim number, it'll spit out a CSV that shows you exactly which ones were updated and you'll get a status message showing um that your entry summary was updated. And um as Callum was saying earlier, these um entries now have the IPA tariffs removed from ACE. So um that's basically saying customs accepted it and um you're good to go. If there's some on there with errors or failed messages, you might get one of these messages. And um it's not always um clear exactly what's wrong with it. The error messages have gotten better um recently. They um oops, sorry. they um the first message the hs relationship sequence

mismatch is the one that we've had the hardest time figuring out is a lot of times it doesn't feel like um there's an error at all when we when we've reviewed the entries but um one example we can I can give is uh there was a 232 exclusion added to the entry and um no uh 232 duties were applied. So, um, customs sees this and they're like, "Well, you excluded yourself from the IPA duties, but you did not declare any 232 duties. " So, when um they went through and um decided later um to refund that entry, they actually rate advanced it with 100% 232 duties. So, there's a lot of little things that um can cause um these errors, but there's usually it's a specific broker that may have um you know known that they had some software issues at the time. Maybe they had to manually calculate um the 15% European duties um or um they just had software issues at the time because CBP basically told the trade community, "Hey, you guys got to calculate this correctly. we can't do it on our end. Um we can't tell you if it's wrong. Um the unable to calculate duty message, that was an early error message, but um it's no longer a message that we're getting. Um we saw it falsely, I think, flag a lot of entries. So if you happen to submit your cape upload in the first uh week or two, I'd recommend maybe and you couldn't figure out what the error was um when you got that failed message. Um, I'd recommend you try to re-upload it into Cape to see if um 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. Um, the goods value amount must be reported on the chapter 1 to 97 line. So, this happens a lot when um maybe you put a value on a 232 line or um a section 301 line um and custom system just can't validate that the entry is correct because um based on their rules, they're not supposed to have a value on there. Um goods value amount on an IEP HTS line, pretty much the same thing um as the previous one. Entry summary and f final liquidation status. Um, that's basically it's past the 80-day deadline that they gave us for phase one. So, you kind of have to wait till phase two for that. Um, no IPA HTS on an entry. Maybe you did use an exclusion and you never actually paid any. Um, one common one they've pointed out in um their CIT updates is um 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, um that one's pretty easily fixable. Overall, um just make sure you review the error with your broker and make sure that um you can try to correct it with a PSC as Kum was saying earlier. And um once the PSC is accepted, then it should be able to go through um into Cape. So after your entries are accepted, what happens now? Well, they've said refunds will be issued within 60 to 90 days from the acceptance date. Um however, we've actually seen the first refunds issued um a lot sooner, like within 3 to four weeks of the first submission. um they're actually issuing refunds on every entry that was liquidated at the time of the Cape upload. And what we kind of think is they've had their chance to review. They had 314 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 CF28s, 29s, or you know, reach out to them and ask questions. um let's just give them that money right now. Um during the meetings with the CIT and CBP, they did originally um asked for a 45day compliance review after the submission. So I think what CBP is doing is they're kind of holding off on paying out any of the unlquidated entries um until they have their 45 days. So we're getting really close. Tomorrow is actually day 45 for um the first CAPE filings that were done on April 20th. So, um we still haven't seen um any requests for compliance reviews or um requests in general on um any Cape claim from CBP, but um my guess is if there are some

we'll start seeing them soon because um that window is closing. Um, 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. Um, but during their meetings with CIT, they did say they wanted to keep the natural liquidation cycle, which we think means that they will refund them in lumps similar to how they refunded um the liquidated entries. But this would also make a lot of entries that filed at the end of 2025 and early 2026 outside of that 60 to 90day window. So, um it's really remains to be seen until we see some kind of pattern. But, um 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 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. All right. So, how can you monitor the refunds? Um, as I kind of said earlier, it's been kind of all over the place. They've been issuing them um the refunds every day of the week. Even Sundays, we've seen some clients get some refunds. Um but you can pull these four reports. These are all um available in your ACE reporting account. Um CBP built all of them um to help um you track things for that they're issuing. Um you can search in your um reports uh section of the ACE just by the um report name. So you might want to take these down. All right. So the ES022, um, this one I find is the most helpful of all four. Um, it gives you kind of a holistic overview of all 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. Um, it'll also show you, um, you know, if there's a 4811 party, which I've highlighted in those first two boxes, if you have a 4811 party, um, designated, that means the refund is going to go to that party. So, um, anytime that populates, you you'll want to make sure that once you see, um, refund information start populating in M through Q, columns M through Q, um, that you reach out to that party and make sure that, um, they keep you aware of, um, when they receive the refund so you can get them from them. Um columns M through Q are usually blank until um they transmit it to the Treasury which is basically custom saying yes these entries are good to go um we're going to send it to Treasury and they can issue the payment. So, in the um columns M through, you'll be able to see the duty amount that you should get back and the interest. Um the refund number, that's important for later. And um the refund date is not entirely accurate. Um we've seen anything from 2 to 12 days from um that date. So, um it's kind of a field I disregard. Um and also the refund status. Um the last column I want to highlight is um if it says transmitted that's good. Um that means the Treasury is working on it or has sent it. Um if it says certified you'll want to run another report that I'll talk about later. But that means um it was likely rejected because you didn't have a refund set up. All right. So, the Rev 603 trade report, this one will show you any refund coming your way. Um, whether it's drawback, PSC's, um, or cape or protest, um, any kind of refund that's being issued to your account will show up on this report. So, um, as you can see here, you can see that, um, there is a cape claim on the second line and it has SAP AC rejected. This is a critical message. If you see this, you'll need to put in some work to make sure your AC refund tab is updated and also reach out to um the

reissue um revenue refunds uh email address, which um 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 613 report AC rejected. So if you see certified in the ESO22 or you see SAP AC rejected on your Rev 603 report, this is where you'll want to um double check and see how much um you could get back. you want to reach out to the revenue refunds um email as soon as you have your AC 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 um and causes you a few extra steps and um they will reissue it to you. And then the rev 615 report is all the details um about a specific cake claim. So if you remember earlier I mentioned the refund ID. This is where you can actually use it. Um 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 ES22. But it's a nice tidy way to show maybe your accounting team or your finance team um exactly what refunds they're getting and why um which entries they go to, which shipments, and um maybe break out the interest and um duty amounts for them so they can kind of reconcile on their end. And those are basically the ways you can um track it. Um hopefully we see some more cadence soon on um exactly what um we can uh expect for the unlquidated entries, but um that remains to be seen. And for some CIT and CBP updates, I'm going to pass it back to Callum to talk about all the uh fun that's happened the last week or so between Thank you, Brian. It is uh an exciting time to be working in the world of trade. Uh quite a few updates over the past couple of weeks and a couple of upcoming deadlines in the next few weeks as well. So, let's dive into it. Uh going to keep some highle updates here. Uh there's quite a bit going on. Uh but let's see. Okay, so one thing to be aware of is May 26th, CBP quietly updated the IPA FAQ page. uh to account for some open questions about entries that are flagged for reconciliation. Uh and according to that, CBP is working on a uh phase solution to process unlquidated or liquidated entries flagged for reconciliation. Uh they also included some suggestions about upload timing to Cape uh and stated that the suggestion is to hold reconciliation filings uh until after Cape processing is complete uh unless you're approaching a deadline in the next 30 days. Uh 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 Cape Phase 1. Uh what this says to me is that CBP is working on the mechanism to include these entries on a subsequent phase uh and these are likely to be included in the next uh phase of cake eligibility. Okay. The following day on May 27th, uh, Judge Eaton with the CIT issued two orders. Uh, the first was asking CBP to come and explain why the CIT shouldn't remove the suspension to require all IPA duties to be immediately refunded. Uh, and demanded that briefs be submitted by all parties by June 4th, which is tomorrow. Uh, and the second was requiring Commissioner Rodney Scott at CBP uh, to appear in person on June 9th and explain CBP CBP's policy. uh and when they're going to comply with the order to requate and refund all entries with IIPA duties. Uh and so this is a little strange and uh it's definitely an escalation from uh Judge Eaton with the CIT. Um, historically we've seen uh 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. Um, so this should be uh interesting to see how this all plays out and keep your eyes on that channel. Uh two days later, the

government did file a motion responding to those two orders from CIT on the 27th. Uh really just requesting uh that either Brandon Lord or Susan Thomas from CBP who were both a little more operationally involved than Commissioner Scott uh replace the commissioner on that June 9th hearing uh just because they'll have more direct knowledge uh of the refund process and hopefully can answer his questions. The second part of that is that the government indicated uh that they intended to appeal the universal injunction on the finally liquidated entries. Uh there's an argument there that CBP has no authority to reliquidate entries and issue refunds uh without an importer specific court order for finally liquidated entries. And as expected uh yesterday evening we saw that the government did issue that appeal. They submitted the appeal and arguing those two points. uh first that CBP Commissioner Scott uh 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. Uh so this was not unexpected uh after reviewing the May 29th order um but is showing that things are moving pretty quickly here. Uh that said, operationally I do not see the appeal here impacting much of uh the entries that are included on CAPE phase 1. So if you have refunds that are already in motion, entries have been accepted in Cape Phase 1 or you've already received those refunds, uh I do not expect there to be a terribly substantial impact from uh this appeal, if at all. What this is really going to impact is entries that would be eligible for uh cape phase 2 or the later phases and is really focused on finally liquidated entries. What that means here is any entry uh that was liquidated more than 90 days in the past. That's what is considered to be finally liquidated entry. Uh it's still an appeal period uh or a protest period that remains open between 90 and 180 days post liquidation. Uh but entries are considered to be finally liquidated after 90 days. Okay. And a couple upcoming deadlines to be aware of as well. Uh as I mentioned before, June 4th, the briefs are due in response to the May 27th order. Uh June 8th was going to be the deadline for the government to appeal, but we have already seen them issue their appeal. Uh so they're getting ahead of that deadline. Uh June 9th is the hearing on those June 4th briefs. Uh this is where Commissioner Scott was directed to appear to answer the questions on the anticipated timing and the policy of CBP in regards to these refunds. Uh the following day uh June 10th is the next progress update on CAPE from CBP. Uh 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, uh the volume of refunds being issued out to importers, uh etc., etc. Uh so that's a good one to monitor as well. And then June 11th, uh there will be a closed settlement conference before the court as well. Uh so there's obviously a lot going on these days and things are changing day by day. Um but it's fascinating to stay on top of. Um and so keep your eye out for more updates coming out from the court. Uh keep your eye out for CSMS messages coming. And we have another uh 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 uh and just cover a couple of ways that Flexboard can help support you in these times. Uh so first off, uh we have a free AI tool that runs a compliance audit on your historical customs entries uh to surface any mistakes, mclassifications, misduty savings. Uh so go ahead and click on the button labeled audit your customs broker above your screen here to get started with that. Uh 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. Uh both fantastic tools and uh worth reviewing to get familiar with. And lastly, if you would like to contact uh get in contact with the flexport team, uh you can email us at classificationflexport. com for any classification or duty rate questions and email us at customsbd flexport. com uh for any questions related to trade advisory duty drawback or brokerage inquiries as well. Uh and with that, welcome back, Mr. Brian. Uh let's jump into some Q& A. Yeah, thanks Cal. Um, let me throw a 4811 question at you. There's a couple here. Um, but I'll kind of summarize both into one. Um

basically they have uh an AC setup, but they're not receiving a refund because their broker is. Um, what can they do to change that? And also um because my broker isn't notified. Okay, that's the question. Okay. Uh it's a good question and it's one we've been receiving quite a bit the last couple of weeks. And so uh for the 4811 notify party, this allows another party to receive the IPA refunds on your behalf. But it's worth noting that the 4811 uh it requires a two-part trigger. And so you have to have the 4811 notify party on file in your ACE account and the broker needs to have uh declared the their uh 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 uh then I would encourage you to contact your assigned center at the C uh to have them revoke the 4811 notify party uh in your ACE account. That should cover it for all future entries. Uh 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 is receiving your refunds without your authorization, I would definitely highlight that to them. It's a good question. — Awesome. — Okay, let's see what else we got here. — Okay, Brian, I got a couple for you. Um, let's see. So, first, what's the status of the entries that have already been liquidated? Uh, is there an update on how those will be handled by Cape? I know you addressed this a little bit, but you want to elaborate? Yeah. So, the ones that are finally liquidated, um, we still haven't gotten any clear guidance on what to do with them. Um, currently you can file a suit with the CIT or protest um to protect your rights to those refunds. Um, neither might be necessary depending on what happens with the appeals. Um, but that's kind of a TBD right now. But those are the two recommended um, actions that you can take right now. All right, let's look for one for you, Callum. Um, appeal question. Um, let's see. Sorry, I'm not uh seeing one that we didn't answer already. Um, 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 they're the importer of record. Sorry, I was asking you, Callum, but then I was questioning it in my own head. Um, if the broker files it as the IR, they should be the one receiving the refunds because all the refunds are going to the importer of record. Um, — I would agree with that. — Yep. 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. — Agree. Um, let me Oh, go ahead. — Yeah, I got one for you about timing. I know this is a question we've been getting quite a bit these days. Uh, so we've received refunds on entries liquidated before April 24th, but nothing after that date. Uh, is that what you're seeing as well? — Yes. So, it's pretty much the only refunds that we've seen come through um are just the liquidated entries at the time of the Cape filing. So, say you file it today, um, anything that was within 80 days of that liquidation, um, 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 um, again, they haven't really provided any guidance to what they're doing. So, um, that's totally normal. Um, let me find one for you. Um, some of my entries came back failed. Oh, wait. Sorry.

If my container arrived in the US on 62425, is it already too late to file or is it included in phase one? — It's a fair question. Um, arrival date is relevant, but really what would hinge this would be hinging on is the liquidation date of the entry. Uh so if this was cleared around June 24th of 25 uh it could be eligible for phase one uh unless this was liquidated sooner than expected. Uh we typically see entries the regular liquidation schedule is 314 days after entry. Uh and then again for Cape phase 1 eligibility this also includes entries that liquidated between 0 and 80 days in the past. this entry would likely be included in Cape Phase 1. Um, but really you should check the liquidation date of that. Uh, if you don't have that handy, uh, check with your customs broker and they should be able to tell you pretty quickly. — Okay, Brian, I got one for you. Um, so does the ES003 report from ACE show only IPA related entries or are there other entries without claims included as well? Yeah. So the ES003 is a general report, so it'll show everything. Um, so you can you'd have to filter out which ones did have which IPA HTS numbers um you did pay duties on. Um there's no need to include the exclusion ones. So like if you used an intransit exclusion um you didn't pay on it. So, it's not um not something you really need to request um a refund on. Um so, yes, you uh you do need to filter down once you do have that um ES003. Um so, question for Callum. Uh, when can we expect CBP to open up eligibilities for entries flagged for reconciliation? — It's a good question. Uh, and we are definitely asking the same. Uh, I don't have a good idea of when they will be opening that up. Uh, 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. Uh 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 K portal. Uh it's a big question and there are quite a few folks who have been pushing CBP to acknowledge this and so this is the first real acknowledgment of uh there being movement in regards to reconciliation filings and entries flagged for reconciliation. Uh so it's certainly something they're working on. Uh but unfortunately we just don't have a concrete date provided to us yet. Uh keep monitoring for CSMS messages as well. Uh they did indicate in the quiet uh 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. Uh there's really good information and you'll be the first to hear. Yes, always monitor the CSMS. — All right. — Okay, Brian, I got another one for you. Uh, so if refund gets sent back to sender due to banking account issues, do you have to resubmit? — You do not have to resubmit your cape claim, but you do have to um basically make sure your AC refund tab is set up correctly. Um there's an email on um that was in the slideshow that you can download um to reach out to uh the refund team to re-trigger it um once you have it set up and then um they'll confirm that they got your message and that you should receive it in four to six weeks. All right. Um let me get one for you, Callum. So, where do you file the 4811s? — 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. Uh, so if you're an importer of record, you will need to submit uh the 4811 information in the notify party section of your ACE importer account. uh you just populate it there and it'll reflect pretty much immediately. Uh if on the other hand you're a customs broker and you want to include the 4811 information on uh your

entry I believe in 2026 version of the 7501 uh I think it's box 28 now used to be box 24 I believe. Uh and you'll include that on uh on the entry every entry you file that you do want to reroute those refunds for. — Awesome. Um, we might have time for one more if uh you want to throw one more at me. — Looks like — um Okay. Uh all right, I got one for you. Uh so, do the Cape refund ACE reports tell you the refund and interest per individual entry? uh or any lump refund received will have to be routed internally uh to different projects accordingly. I think it's really about reconciling refunds at the entry level. Uh which ACE report can you use to identify what amounts are being received for which entries. — Got it. Yeah. So the ES22 um definitely shows you a breakout. There's a column for the refunded duty and a d interest per entry. So you can um match that up to um whatever you're seeing on your report that you pulled before um you did the cape upload. Um also there's um a refund ID. So each refund ID um corresponds to the remittance. So if you there's three refund IDs, those will be three separate AC um transactions that custom sends you. So you can kind of group it to make sure that each one um you receive the correct amount. We have seen some that um are actually a little different and um I would recommend reaching out immediately to the refunds email just to see why there's a discrepancy between the two numbers because um only CBP can really explain that one. But um thank you everybody for joining us. Um this concludes today's webinar. We'll email everyone a link and um to the recording tomorrow morning. Uh, thank you again for joining us and have a great day.