IEEPA Tariff Refunds: How the Process Works (UPS & FedEx Explained)

Who files, who gets paid, and where shippers get stuck

Tariffs tied to IEEPA (International Emergency Economic Powers Act) have been a moving target. Both UPS and FedEx have now published guidance on how refunds are being handled, but the process depends on who acted as the Importer of Record (IOR) and how the entry was filed.

Just as important: the current process reflects Phase 1 of CBP’s refund program, which has specific eligibility requirements and timelines.

Start Here: Who Was the Importer of Record?

The refund process hinges on one key detail:

Who was listed as the Importer of Record (IOR)?

CBP issues refunds to the IOR. From there, funds are passed through to the appropriate party depending on how the shipment was handled.

1. If UPS Was the Importer of Record

UPS guidance indicates they will handle the refund process for shipments where UPS served as the Importer of Record. In those cases, UPS will:

• Submit refund claims through CBP
• Process the refund once received
• Credit the funds back to the customer

If UPS acted only as customs broker and not the IOR, their guidance does not indicate that they will manage the refund process.

2. If FedEx Acted as Customs Broker

FedEx has taken a more active role in the current Phase 1 process. Based on their published guidance, FedEx:

• Is submitting refund claims via the CAPE tool within the ACE Portal
• Is prioritizing submissions based on liquidation timing
• Will issue refunds to customers once funds are received from CBP

This applies to shipments where FedEx served as customs broker.

3. If You Used a Third-Party Customs Broker

If a separate broker handled the entry:

• The broker is responsible for filing the refund
• Claims are submitted through CBP systems (currently CAPE for Phase 1)
• You may need to provide authorization or confirm eligibility

Caution: This is where delays often occur. The carrier is out of the loop, and the process depends entirely on your broker’s execution.

4. If You Filed Import Documentation Yourself

If your team handled the entry directly:

• You are responsible for submitting the refund request
• Phase 1 claims are filed via the CAPE platform in the ACE Portal
• Submissions are made by uploading eligible entry numbers (typically via CSV), with CBP performing automated validation

Caution: Most shippers underestimate the effort required. It still requires:

• Familiarity with CBP processes
• Accurate entry identification and data integrity
• Active tracking of submission status and outcomes

Important: Phase 1 Limitations

The current refund process reflects Phase 1 of CBP’s IEEPA refund program, which:

• Applies to certain unliquidated entries and entries liquidated within approximately 80 days
• Requires submission through the CAPE tool in ACE
• Follows CBP review and validation before funds are issued

Processing timelines can vary, but refunds are generally expected within approximately 60 to 90 days after acceptance, depending on CBP review.

The Hidden Risk: Missed Refunds

The biggest issue isn’t that refunds can’t be claimed, it’s that they’re never claimed at all because:

• Ownership is unclear
• Documentation is fragmented
• Teams assume “someone else is handling it”

In many cases, that assumption is wrong. In others, eligibility windows are missed entirely.

What Shippers Should Do Now

If IEEPA tariffs have impacted your shipments, it’s worth asking:

• Who acted as Importer of Record across our shipments?
• Which parties are responsible for filing refund claims?
• Do we have confirmation those claims have been submitted?
• Are we tracking refunds through to completion?

If you don’t have clear answers, there’s a good chance money is sitting unclaimed.

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For more information from UPS and FedEx visit: 

https://www.ups.com/us/en/shipping/international-shipping/tariffs/tariff-refunds

https://www.fedex.com/en-us/shipping/international/us-tariffs-impact.html

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