CAPE Phase 1 is open·Form 19 deadline: Aug 2026·Updated Apr 20, 2026
ES-003

Am I the Importer of Record?

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TL;DR – The Importer of Record (IOR) is the legal entity that filed your customs entry and paid the duties. Only the IOR can file a CAPE Declaration and receive the refund. Check the IOR field on your CF-7501 Entry Summary. If it shows FedEx Logistics, DHL, or Amazon AGL instead of your company name, you are not the IOR on those entries.

What Is the Importer of Record?

The Importer of Record is the party legally responsible for a customs entry – the entity that filed the Entry Summary with CBP and paid the duties. For the IEEPA refund, this matters entirely: CBP will only issue the refund to the IOR on record. If you're not the IOR, you cannot file a CAPE Declaration for that entry.

This catches a significant number of importers off guard. The company that bought the goods and paid the supplier is not always the IOR. If your supplier shipped DDP (Delivered Duty Paid), their freight forwarder likely acted as IOR. If you used FedEx or DHL air freight, their logistics subsidiary may have been listed.

How to Check – Find Your CF-7501

The CF-7501 Entry Summary is the CBP form that records who filed each entry. The IOR is listed explicitly in the Importer of Record field, typically near the top of the form.

How to find your CF-7501:

Your customs broker should have copies of all CF-7501 forms they filed on your behalf. Request them by entry number or date range. If you filed entries yourself through ACE Portal, you can pull them directly from your account. If you're unsure who your broker was for older entries, check your freight invoices – the broker's name and contact information are usually there.

Once you have the CF-7501, look for the Importer of Record field. Your company name should appear there. If it shows a third-party logistics company instead, you are not the IOR on that entry.

Common Cases Where You Are Not the IOR

FedEx Logistics Inc

If you shipped goods via FedEx air freight under DDP terms, FedEx Logistics Inc (formerly FedEx Trade Networks, renamed in January 2019) may appear as the IOR. FedEx Logistics is FedEx's customs brokerage and trade services arm – it acts as IOR on DDP air shipments where the supplier arranged clearance.

If FedEx Logistics is listed as IOR on your entries, the IEEPA refund goes to FedEx, not to you. Whether you can recover those duties depends on how FedEx structured the billing: if duties were listed as a separate line item on your FedEx invoice, there may be a passthrough path through FedEx's refund policy. If duties were bundled into freight charges, recovery is more complex.

DHL Express / DHL Global Forwarding

DHL operates its own brokerage structure. If you shipped DDP via DHL, either DHL Express or DHL Global Forwarding may appear as IOR depending on the service used. DHL has no connection to FedEx's structure – they are entirely separate entities with separate brokerage operations.

The same principle applies: if a DHL entity is listed as IOR, the refund goes to DHL. Check your DHL invoices to see whether duties were billed as a separate line item.

Amazon AGL

If you sell on Amazon and use FBA with Amazon's Global Logistics (AGL) service for inbound freight, Amazon may appear as the IOR on your shipments. Amazon AGL manages customs clearance as part of the service, which means Amazon – not you – is the legal IOR on those entries. The IEEPA refund for those entries belongs to Amazon.

Supplier's Freight Forwarder

Under DDP Incoterms, the supplier is responsible for customs clearance and duty payment. The supplier typically appoints a freight forwarder who acts as IOR. You received the goods and paid the supplier's invoice (which included duties in the price), but the IOR on the CBP record is the forwarder – not you.

What to Do If You're Not the IOR

Your options depend on which third party is listed:

FedEx Logistics: Contact FedEx Trade Networks/Logistics customer service and ask about their IEEPA duty refund passthrough policy. Ask specifically whether duties on your shipments were billed as a separate line item – this determines whether there's a recovery path for you.

DHL: Same approach – contact DHL Express or DHL Global Forwarding depending on which entity filed your entries. Ask about their IEEPA refund policy for DDP customers.

Amazon AGL: Amazon has not publicly announced a passthrough mechanism for IEEPA refunds to FBA sellers. Monitor Amazon's seller communications for any updates.

Foreign IOR without a US bank account: CBP has not provided a solution for foreign entities acting as IOR who cannot enroll in ACH. This remains an open question as of April 2026. Contact IEEPARefunds@cbp.dhs.gov for the latest guidance.

Supplier's freight forwarder: Contact your supplier and ask them to pursue the refund through their forwarder. The refund legally belongs to whoever was IOR – that's between you and your supplier to resolve commercially.

Frequently Asked Questions

My supplier shipped DDP – who gets the refund? The IOR gets the refund. Under DDP terms, the supplier or their forwarder is typically listed as IOR, not you. Check your CF-7501 to confirm. If a third party is listed, the refund goes to them – your recourse is to negotiate with your supplier to pass it through.

FedEx Logistics is listed as IOR on my entries – can I still recover the duties? Possibly, but not directly through CAPE. FedEx Logistics would file the CAPE Declaration as IOR and receive the refund. Whether they pass it to you depends on how duties were billed: if they appeared as a separate line item on your FedEx invoice, contact FedEx Logistics about their refund passthrough policy.

How do I find my CF-7501 if I don't have a copy? Request copies from your customs broker – they are required to keep entry records for five years. If you don't know who your broker was, check your freight invoices or shipping documentation. Entry numbers appear on most freight paperwork and can be used to request the CF-7501 from your broker or directly through ACE Portal if you have importer account access.

What is CBP Form 4811? Form 4811 is a CBP form that designates a third party – typically a customs broker – as the recipient of a refund payment on behalf of the IOR. If your broker is filing CAPE for you and you want the refund sent directly to them for processing, they'll need a Form 4811 on file. This is different from the IOR situation above – Form 4811 applies when you are the IOR but want your broker to receive and manage the payment.