Five stages,meticulously executed.
The CAPE Declaration is the defined administrative pathway for U.S. importers to recover duties paid under the IEEPA tariff regime during the eligibility window. Below is how we run it. [DRAFTED — subject to firm review.]
Eligibility window: duties paid Feb 2025 – Feb 2026
A documentation exercise, executed with care.
There is no novel legal theory to construct here. The ruling did the legal work. What remains is a documentation and filing exercise — one that rewards diligence and punishes sloppiness. Our job is to run it with the rigor a CBP submission demands.
- 01/ 05
Stage 01
Eligibility review.
We start with a no-cost review of your import activity during the eligibility window. The goal is simple: confirm there is a recoverable position worth the work, and identify any documentation gaps before they become problems.
- 1Light-touch review of entry summaries and duties paid
- 2Initial estimate of recoverable amount and timeline
- 3Documentation readiness assessment
- 4Clear yes / no recommendation at the end — we decline cases we cannot meaningfully help with
- 02/ 05
Stage 02
Duty and entry reconstruction.
Once engaged, we reconstruct the complete duty-payment history across the eligibility window — entry by entry, line by line. This is the foundation of the filing, and the stage where careful work pays off.
- 1Entry summary (CBP 7501) collection and validation
- 2Commercial invoice and proof-of-payment cross-checks
- 3HS classification review for each line affected
- 4Reconciliation against your broker's records to catch missing entries
- 03/ 05
Stage 03
CAPE Declaration preparation.
We prepare the CAPE Declaration package to the documentation standard CBP expects. Every assertion is backed by primary source documents; every number is traceable.
- 1Declaration drafted and internally reviewed
- 2Supporting documentation assembled and indexed
- 3Your team reviews and approves before filing
- 4Filing coordinated with your licensed customs broker, who remains filer of record
- 04/ 05
Stage 04
CBP submission and review.
The filing is submitted through your broker. We track the submission through CBP review and respond to any information requests on your behalf — promptly, in writing, with the receipts attached.
- 1Active monitoring of CBP queue and status
- 2Rapid response to CBP information requests (CF-28, CF-29)
- 3Coordination with your broker through any back-and-forth
- 4Weekly status update, or on any material change
- 05/ 05
Stage 05
Refund disbursement and closeout.
When CBP approves the recovery, we confirm the refund has been issued, reconcile against your projected amount, and close the engagement with a complete documented record of the filing.
- 1Refund confirmation and reconciliation
- 2Full documentation archive handed to your team
- 3Debrief call to review the filing record
- 4Retention of records to the standard required by CBP and the engagement
The eligibility review costs nothing. It takes about a week.
If there is a recoverable position worth pursuing, we tell you. If there is not, we tell you that too — and make no attempt to sell you anything else.