FedEx, UPS or DHL was importer of record: who gets the IEEPA refund?
As of
CBP pays an IEEPA refund to the importer of record on the entry. If FedEx, UPS or DHL was importer of record, the refund goes to the carrier first, and you recover it from the carrier, not through your own CAPE Declaration.
Why the carrier is in the middle
Only the importer of record, or the licensed customs broker who filed the entry, can file a CAPE Declaration. CBP checks that the importer of record number on your ACE account matches the one on each entry summary, and rejects the entry with "Account Mismatch" when it does not.
Express carriers are often importer of record on small parcels and on shipments sent delivered duty paid. In that case the entry carries the carrier’s importer number, not yours, even though you paid the duty on the carrier’s invoice.
How to tell who was importer of record
Look at the importer number on the entry summary (CBP Form 7501) or on the carrier’s duty invoice. If it is your EIN-based importer number, you were importer of record and CAPE is open to you. If it is the carrier’s, the refund is the carrier’s to collect.
Entries you filed through your own broker under your own importer number are yours, even if the goods moved on a FedEx or DHL airway bill.
What each carrier has said
As reported in May 2026: UPS said it would request refunds on entries where it was importer of record and pass them to the payer without any action from the customer. FedEx said that if refunds are issued to FedEx, it will refund the shippers and consumers who bore the charges. DHL said it passes through only what it receives from CBP, and for some entries asks the customer to authorize it to file.
Brokerage and processing fees charged when the duty was collected are generally not part of the refund. Check the carrier’s current terms, since these statements have changed over the year.
What to do
- List the entries a carrier cleared for you in 2025, with airway bill numbers and the duty on each invoice.
- Confirm the importer of record on each one from the 7501 or the duty invoice.
- Do not put carrier-IOR entries on your own CAPE Declaration: CBP will reject them as an account mismatch.
- Write to the carrier with the list and ask for the IEEPA refund status of each entry and the date it will be passed through. Keep a copy.
- For entries where you were importer of record, check the refund window: CAPE takes unliquidated entries and entries liquidated within the last 80 days.
Sources
FluxFina prepares documents for the importer of record or their licensed customs broker. It is not legal or customs advice, and FluxFina never files with CBP. Only the importer of record or its broker can file a CAPE Declaration or a protest.