FedEx and UPS Tariff Refunds: What Small Importers Should Do Now

Updated May 5, 2026. FedEx and UPS have both moved from general tariff-refund statements to carrier-specific refund processes. That is good news for small importers, but it does not mean every business should expect an immediate credit or a refund that matches the original shipping invoice.

FedEx says it began submitting CAPE Declarations on April 20, 2026, for Phase 1-eligible entries where FedEx served as customs broker. UPS says that for shipments where UPS was the Importer of Record, it will request IEEPA tariff refunds from CBP and issue refunds to payors after UPS receives funds from CBP. In both cases, the timing still depends on CBP acceptance, CAPE phase rules, liquidation status, and the carrier’s internal refund process.

This article is for owners, finance leads, ecommerce teams, and bookkeepers who paid tariff charges through carrier invoices and now need to make sense of what happens next. It is not legal advice or customs brokerage advice. DeMar Consulting Group helps businesses organize the accounting, cash-flow, and documentation side so refund decisions do not turn into month-end guesswork.

What Changed With FedEx and UPS Refunds

The carrier updates matter because many small importers did not file entries directly. They paid duties and related charges through shipping invoices, carrier billing accounts, or customer reimbursement workflows. In those cases, the party that paid the invoice may not be the same party that files the CAPE Declaration or receives the first refund from CBP.

FedEx says it will issue IEEPA tariff refunds to shippers and consumers who originally bore those charges once FedEx begins receiving refunds from CBP, for customers where FedEx served as customs broker. FedEx also says it is prioritizing submissions based on liquidation dates and that final refund amounts will not be available until CBP accepts submissions.

UPS says Phase One applies only to certain tariff payments and pending tariff payments, and that UPS will request and retrieve IEEPA tariff refunds for shipments where UPS was the Importer of Record. UPS says payors do not need to contact UPS in those cases, but it cannot issue refunds until CBP pays UPS.

The practical takeaway: your next step depends on the role your company played on the entry. Do not assume “FedEx is refunding” or “UPS is refunding” answers your specific accounting question.

Start With Importer-of-Record Status

The Importer of Record controls a lot of the refund path. If your business was the Importer of Record, you may need to pursue the refund directly through CBP, usually with your customs broker or trade advisor. If FedEx or UPS held the importer or broker role for the entry, the carrier may submit the CAPE Declaration. The carrier may then refund the payor or customer under its own process.

Pull the entry summary, usually CBP Form 7501 or carrier-provided entry documentation. Look for the Importer of Record name, address, importer number, broker, entry number, entry date, liquidation status, and tariff lines. Then compare that record to the invoice that your company paid.

For a clean internal tracker, add these columns:

• Carrier or broker name.
• Importer of Record.
• Payor on the carrier invoice.
• Customer or entity that economically bore the tariff cost.
• Entry number and date.
• IEEPA duty amount identified.
• Other duties, tariffs, brokerage fees, freight, and administrative fees.
• CAPE status or carrier refund status.
• Expected accounting treatment.

This small worksheet can prevent a lot of confusion. It tells the owner which refunds may come from a carrier credit, which may need direct CBP work, and which should stay out of the cash forecast for now.

Why “No Action Required” Still Requires Records

UPS tells customers to wait for shipments where UPS was the Importer of Record. That helps operations. It does not create a finance file. Your team still needs support for paid amounts, possible refunds, original book treatment, and ownership.

FedEx also says customers may see partial refunds because the Supreme Court decision affected IEEPA tariffs, not every tariff or duty. A carrier refund may arrive as a credit or payment that is smaller than the original invoice. Without invoice-level support, the accounting team has to guess at the gap. It could come from a nonrefundable charge, delayed entry, rejected entry, Section 301 duty, brokerage fee, or carrier timing issue.

Keep records before the credits arrive. Save the original invoice, payment support, entry documents, carrier tariff notices, emails, account credits, and any customer reimbursement notes. If a refund shows up later, the month-end close should not depend on memory.

What Small Importers Should Do Now

First, identify the population. Search FedEx, UPS, and broker invoices for IEEPA, tariff, duty, customs, disbursement, advancement, brokerage, and import charge language. Then isolate entries from the period covered by current CAPE Phase 1 guidance. Do not lump all international shipping costs into one refund estimate.

Second, sort entries by refund path. Entries where your business was the Importer of Record may need direct CBP, ACE, ACH, broker, or trade counsel work. Entries where a carrier was the Importer of Record may need carrier-status tracking and accounting support. Entries outside Phase 1 should move to a later-phase or unresolved bucket, not base-case cash.

Third, update the forecast. Treat carrier refunds as expected credits only after you know the carrier role, the duty type, the entry status, and whether the carrier has received funds from CBP. If the refund is material, show a base case, delay case, and no-refund-this-quarter case. Our guide to tariff refunds and cash-flow planning gives a fuller cash model.

Accounting Questions to Answer Before the Credit Arrives

A carrier refund can land as a statement credit, invoice adjustment, ACH payment, or customer-level credit. Your accounting treatment should follow the original cost and the refund support, not the memo line alone.

Ask these questions before recording the refund:

• Was the original tariff cost recorded in inventory, cost of goods sold, freight, customs duties, or another expense account?
• Did the company pass the tariff cost through to customers as a surcharge, price increase, or reimbursement?
• Is the refund for IEEPA duty only, or does the carrier credit include interest, offsets, or other adjustments?
• Does the refund relate to goods still in inventory or goods already sold?
• Should management use the refund to reduce current expenses, adjust inventory, affect gross margin, or support separate reporting?

If the original duty costs sit across several accounts, start with how to account for a tariff refund in your books. A clean refund file is easier to defend than a year-end cleanup project built from old carrier statements.

When to Ask for Help

Bring in your customs broker or trade counsel when the question is eligibility, filing authority, liquidation status, protest rights, drawback, reconciliation, or whether an entry belongs in a later CAPE phase. Bring in your CPA when the question is tax timing, financial statement treatment, inventory accounting, or customer reimbursement obligations.

DeMar Consulting Group can help with the finance layer: gathering invoices, mapping carrier charges to entries, reconciling the general ledger, building refund scenarios, and preparing a decision file for management. The goal is not to chase every possible credit. The work should separate likely refunds, delayed refunds, nonrefundable charges, and open questions before anyone books the money.

Sources

• FedEx: Navigating U.S. tariffs and customs regulations
• UPS: IEEPA Tariff Refund Process
• CBP: International Emergency Economic Powers Act (IEEPA) Duty Refunds
• AP: FedEx says it will return tariff refunds to customers