As the IEEPA tariff refund process moves forward through CBP’s CAPE system, we are now seeing clear (but not identical) positions from the major carriers—UPS, FedEx, and DHL—on how refunds will be handled.

This matters because for many importers, the carrier—not the business—was the Importer of Record, meaning refunds will flow through the carrier first. Please double-check who the importer of record is when FedEX, UPS and DHL are involved.

If your name and address are listed in the Importer of Record box on the entry summary form (customs form 7501), then you are the IOR. If the (FedEx, UPS, DHL) name and address are listed in the Importer of Record box, then FedEx, UPS, or DHL is the IOR.

1. What the carriers are actually saying

UPS has taken the clearest position:

• “There is no need… to contact UPS.”
• UPS will “request and retrieve IEEPA tariff refunds… on our customers’ behalf.”
• “After we receive the funds… we will issue refunds to the payors.”
• “No further action is required at this time.”

Important additional point:
UPS has also clarified that fees assessed at the time tariffs were originally collected (e.g., brokerage or processing fees) are not eligible for refund.

Takeaway:
If UPS was your Importer of Record, you should not need to take additional action—but you should still monitor and document your entries.

FedEx has stated:

• It has “committed to [filing] on behalf of all customers for whom we served as customs broker.”
• Customers “do not need to run [their] own reports.”
• “If refunds are issued to FedEx, we will issue refunds… to the shippers and consumers who originally bore those charges.”
• FedEx is prioritizing its submissions based on liquidation dates.

Takeaway:
FedEx is functionally taking the same approach as UPS, but with more conditional language.
If FedEx acted as broker/Importer of Record, it is expected to handle filings and pass through refunds.

DHL has taken a more cautious approach:

• It will “refund only those IEEPA tariffs that it receives back from CBP.”
• It notes there is still “no formal government guidance” and “more questions than answers.”
• It “may be able to assist” with refund requests.

For shipments where customers served as IOR, there are two options available from DHL

1. If DHL provided customs brokerage services only, refund claims can be initiated by the customer (IOR) directly through CBP’s processes (CAPE) or through an authorized representative.
   Or

2. If DHL provided customs brokerage services, the customer can request DHL to file the refund claim on their behalf for eligible shipments where they acted as the Importer of Record (IOR). DHL will require either a list of eligible AWBs or the associated entry numbers. A standard Import Paperwork Fee will apply.

Note: DHL Express will not file IEEPA refund claims for shipments where the customer acted as the Importer of Record (IOR) unless authorization is provided.

Takeaway:
DHL has not yet committed to a fully automatic, carrier-driven process. Customers using DHL should be especially attentive and prepared for possible follow-up steps.

2. Timing: No refunds before mid-May

CBP has indicated that the first round of refund payments is expected to be transmitted on or around May 11–May 14.

That means:

• No legitimate refunds will be received before that timeframe
• Carriers themselves must first receive funds from the government before passing them through

3. Warning: Be cautious of “immediate refund” offers

We are already seeing reports of third parties offering to:

• “Accelerate” refunds
• Provide “immediate payouts”
• Charge contingency or processing fees

Be very cautious.

If someone is promising:

• Immediate refunds before mid-May, or
• Guaranteed expedited payments

there is likely a catch, including:

• High contingency fees
• Assignment of your refund rights
• Unnecessary or duplicative filings

Reminder:
If your carrier was the Importer of Record, you generally cannot file directly with CBP anyway—so third-party “filing” services may not apply to your entries.

If you encounter:

• Aggressive outreach
• Unclear fee structures
• Requests to assign your refund rights

Please flag it. We are actively tracking potential predatory practices in this space.

4. What you should do now

Even if no action is required, you should:

✔ Confirm Importer of Record status

• Was it you—or the carrier?

✔ Gather your records

• Entry numbers
• Tracking numbers
• Invoices showing tariff charges
• Proof of payment

✔ Monitor your carrier

• Watch for communications from UPS, FedEx, or DHL
• Track whether refunds are received and passed through accurately

✔ Do not duplicate filings

• If the carrier was Importer of Record, do not file independently unless specifically advised

5. Bottom line

• UPS: No action required; refunds will be handled and passed through (excluding certain fees)
• FedEx: Same approach in practice, but framed more conditionally
• DHL: Process still developing; monitor closely

And most importantly:

No one is getting refunds before mid-May. If someone says otherwise, proceed with caution.

If you have specific issues, errors, or are seeing questionable refund offers, please reach out so we can raise them with CBP and the court as appropriate.