What to Do If You Paid IEEPA Tariffs Through FedEx, UPS, or DHL

Many small businesses did not pay IEEPA tariffs directly to the government. Instead, carriers like FedEx, UPS, and DHL advanced those duties on their behalf and then billed them.

This creates a critical question:

If refunds are issued, who actually gets the money—and how do you make sure you receive it?

Key Principle: Who Gets the Refund First

Refunds from U.S. Customs and Border Protection (CBP) go to the:

Importer of Record (IOR)

In many express shipments:

• The carrier (FedEx, UPS, DHL) is the Importer of Record
• NOT the small business that ultimately paid the tariff

That means:

Your refund may go to the carrier first—not to you

What the Carriers Have Said

FedEx

• Has publicly stated it will pass refunds back to customers
• Has taken legal action seeking refunds (including interest)
• No details yet on timing or process

UPS

• Says it will support customers in obtaining refunds
• Has not committed to automatic pass-through payments

DHL

• Has not issued clear public guidance on refunds
• Likely awaiting CBP procedures before acting

What to Expect: Industry Practice and Reassurance

There is strong precedent for third-party intermediaries—like carriers and customs brokers—to return overpaid duties to the parties that ultimately bore the cost.

In prior customs scenarios:

• When duties were refunded to a carrier or broker acting as Importer of Record,
• Those funds were reconciled and returned to the customer who originally paid them

This reflects standard industry practice and basic commercial expectations.

You should expect that carriers will establish processes to return refund money to their customers once the CBP refund system is operational.

These companies already maintain systems for:

• billing reconciliation
• duty adjustments
• customer reimbursements

And once the government finalizes the refund mechanism, carriers are expected to:

• implement structured processes
• match refunds to original transactions
• distribute funds back to customers

Important Reassurance

Carriers are not expected to retain refund money that was paid by their customers.

There is:

• no business incentive to do so
• significant legal and reputational risk if they attempted it

And notably:

• FedEx has already publicly confirmed its intent to pass refunds through to customers

What You Should Do Now

1. Identify Who Was the Importer of Record

Review your shipping documentation:

• Customs entry forms
• Commercial invoices
• Carrier billing statements

Look for:

• “Importer of Record”
• “IOR”
• Broker listed on entry

If the carrier is listed → they will receive the refund first

2. Gather Your Records (Do This Immediately)

Compile the following:

• Entry numbers (CBP Entry IDs, if available)
• Shipment tracking numbers
• Invoices showing tariff charges
• Proof of payment to carrier
• Dates of import

You may need this to claim or verify your refund later

3. Contact Your Carrier Now

Send a written inquiry asking:

• Whether they were the Importer of Record
• Whether they intend to:
  • claim refunds on your behalf
  • pass those refunds through to you
• What documentation they will require from you
• Whether you need to take any action now

Do not assume refunds will be automatic

4. Monitor Refund Process Developments

The refund system (through CBP’s CAPE process) is still being implemented.

Watch for:

• Formal CBP guidance
• Carrier-specific instructions
• Deadlines or submission requirements

TERRA will continue to track and publish updates.

5. Do NOT File Separate Refund Claims Yet (In Most Cases)

If the carrier is the Importer of Record:

• You likely cannot file directly with CBP
• Filing separate claims may:
  • be rejected
  • create duplicate/conflicting claims
  • delay the process

The correct path will depend on how CBP structures carrier-based refunds

Risks to Be Aware Of

• No standardized process exists yet for carrier pass-through refunds
• Carriers may:
  • require documentation
  • impose administrative processes
  • take time to reconcile payments
• Refunds may not include:
  • brokerage fees
  • service charges
• The timing and mechanics are still being developed

Bottom Line

If you paid tariffs through a carrier, your refund may go to the carrier first—but you should expect those funds to be returned to you once the process is established.

The key issue is not whether refunds will be passed through, but: how efficiently and transparently that process will work