DDP Shipments and Courier as IOR – What Happens to Your Refund?
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TL;DR – Under DDP shipping terms, the supplier or their freight forwarder is typically the Importer of Record – and the IEEPA refund goes to whoever is IOR. If FedEx Logistics or DHL is listed as IOR on your entries, the refund belongs to them. Your recovery path depends on how duties were billed on your freight invoice.
How DDP Affects Who Gets the Refund
DDP – Delivered Duty Paid – is an Incoterms shipping arrangement where the supplier takes responsibility for customs clearance and duty payment. The goods arrive at your door with duties already paid and included in the invoice price.
The problem for IEEPA refunds: the entity that paid the duties to CBP – the Importer of Record – is the entity entitled to the refund. Under DDP terms, that's not you. It's whoever your supplier appointed to handle clearance, typically their freight forwarder or the courier's logistics arm.
You cannot file a CAPE Declaration for entries where you are not the IOR. The refund legally belongs to the IOR on the CF-7501 record.
FedEx Logistics as IOR
When goods arrive via FedEx air freight under DDP terms, FedEx Logistics Inc frequently appears as the IOR. FedEx Logistics (formerly FedEx Trade Networks until January 2019) is FedEx's customs brokerage and trade services division. It acts as IOR on DDP air shipments where the shipper arranged clearance through FedEx's integrated service.
If your CF-7501 shows FedEx Logistics Inc as IOR, FedEx is entitled to the IEEPA refund on those entries – not you.
Your recovery path depends on billing structure. Check your FedEx invoices for the shipments in question:
If duties appeared as a separate line item on your FedEx invoice – labeled as customs duties, tariffs, or similar – FedEx billed you for those duties specifically. In that case, contact FedEx Logistics customer service and ask about their IEEPA duty refund passthrough policy. FedEx received the CBP refund; you paid FedEx for those duties; the passthrough argument is clear.
If duties were bundled into the freight charge with no separate line item, the situation is more complex. You'll need to work with FedEx to determine whether those charges can be attributed to IEEPA duties specifically.
DHL as IOR
DHL operates its own independent brokerage structure – DHL Express for express shipments and DHL Global Forwarding for freight. DHL has no connection to FedEx's operations. If your DDP shipments came via DHL, a DHL entity – not FedEx Logistics – will appear as IOR on your CF-7501.
The same principle applies: DHL received the IEEPA refund as IOR. Contact DHL Express or DHL Global Forwarding (depending on which entity appears on your CF-7501) and ask about their policy for passing through IEEPA duty refunds to customers who were billed for those duties separately.
Foreign IOR Without a US Bank Account
A separate but related problem: importers with a foreign IOR who have no US bank account cannot complete ACH enrollment in ACE Portal. ACH enrollment requires a US bank account, and CBP's refund system is built around electronic ACH payments.
As of April 2026, CBP has not provided a public solution for this situation. The question came up during CBP's official CAPE webinar and was not answered. Foreign entities acting as IOR who cannot enroll in ACH face an unresolved barrier to receiving their refund.
If this applies to you, contact CBP directly at IEEPARefunds@cbp.dhs.gov and describe your situation. This is the most current guidance available – CBP may address it in a future CSMS notice or Phase 2 guidance.
Frequently Asked Questions
Can I force my supplier to pass through the refund? Not through CBP. The IEEPA refund is a matter between CBP and the IOR – CBP doesn't get involved in commercial disputes between buyers and suppliers about who ultimately should benefit from the refund. Your leverage is commercial: if your supplier or their forwarder is IOR and receives a refund for duties that were passed through to you in the invoice price, you can pursue that as a contractual matter. Many suppliers are cooperating voluntarily.
What if FedEx or DHL won't pass through the refund? You have limited options through CBP. The refund legally belongs to whoever is IOR. If FedEx or DHL received it and declines to pass it through, your recourse is a commercial or legal dispute with them – not a CBP process. Document clearly that duties were billed to you as a separate line item, as this is the strongest factual basis for a passthrough claim.
Is there a deadline for the DDP refund passthrough? No CBP deadline applies to commercial passthrough arrangements between you and FedEx, DHL, or your supplier. The CAPE filing deadlines apply to the IOR (in these cases, FedEx, DHL, or the forwarder) – not to you. That said, the sooner you contact them, the more likely they are to engage before their own CAPE filing window closes.
My supplier shipped DDP but I want future shipments as IOR – how? Negotiate a change to EXW or DAP Incoterms with your supplier, under which you arrange customs clearance and become the IOR. Work with your own customs broker to set up ACE Portal access and a power of attorney arrangement. This won't affect your existing IEEPA entries but positions you correctly for future refunds.