If you purchased imported goods under DDP (Delivered Duty Paid) terms, you likely paid tariffs indirectly—but you may not automatically receive the refund.

Under CBP’s refund process (including CAPE filings), refunds go to the party that paid duties in CBP’s system, not necessarily the business that bore the cost.

That means:

• Your supplier, customs broker, or carrier (FedEx/UPS/DHL) may receive the refund first
• You may need to take action to ensure the money gets back to you

What CBP/CAPE Means for You

• Refunds are issued through CAPE (Consolidated ACE Processing Environment)
• ACH enrollment is required to receive funds
• Refunds are tied to:
  • The Importer of Record (IOR)
  • The payer of duties on the entry
• Interest is calculated under 19 U.S.C. § 1505 from date of payment to liquidation

Checklist: What to Do Now

1. Identify Who Was the Importer of Record (IOR)

This is the most important step.

Check your:

• Commercial invoice
• Entry summary (CBP Form 7501)
• Broker or carrier records

Ask:

Was it you, your supplier, or a third party?

2. Confirm Who Actually Paid the Duties

Even under DDP, payment may have been made by:

• Your foreign supplier
• A carrier (FedEx, UPS, DHL)
• A customs broker
• (Less commonly) a surety

This determines who CBP will send the refund to first.

3. Determine If You Are Set Up in CAPE + ACH

If you are the IOR or expect to receive funds:

• Confirm you are registered in CAPE
• Confirm ACH banking is correctly set up

Without this, you will not receive refunds directly.

4. Contact Your Supplier or Carrier Immediately

Do not wait for refunds to process.

Send a simple inquiry:

• “Were you listed as the importer or duty payer?”
• “If refunds are issued, what is your process for returning them?”

For carriers:

• Ask how they will handle duty drawback/refund pass-throughs

5. Review Your Purchase Agreements

Look for terms addressing:

• Duties and taxes
• Refund ownership
• Reimbursement obligations

If silent, you may need to:

• Negotiate or document expectations now

6. Keep Records of All DDP Transactions

Maintain:

• Invoices
• Shipping records
• Entry numbers
• Communications with supplier/carrier

This will be critical if:

• Refunds are misdirected
• You need to trace or recover funds

7. Coordinate Before Filing (If You’re Filing Claims)

If your business is filing for refunds:

• Ensure alignment between:
  • You
  • Your broker
  • The actual duty payer

Duplicate or conflicting filings may:

• Delay refunds
• Create disputes

Key Takeaway

If you bought goods DDP, you likely paid the tariffs—but CBP will refund whoever paid them on paper.
You need to identify that party and make sure the money flows back to you.