Ouli Refund / Guides

Guide · Non-IOR sellers

The refund landed. It landed somewhere else.

If you sold on DDP terms and your forwarder's US entity was the importer of record, CBP's refund goes to that entity, not to you. This follows from how CBP pays: only the importer of record or the broker who filed the entry summaries may file, and payment is made to the account on that record. Whether the money is then owed onward to you is a contract question between you and your counterparty — not something CBP adjudicates — and it turns on your specific agreements and documents.

PUBLISHED 2026-08-31 · FIGURES FROM CBP COURT FILINGS AND PUBLIC RECORDS, AS OF JULY 2026

Who CBP pays
The importer of record on the entry. Under DDP or "double-clear, tax-included" arrangements, that is commonly the forwarder's US entity.
Who may file
The importer of record, or the licensed customs broker who filed the entry summaries. A seller who is not the IOR cannot initiate a claim.
What decides the outcome
The contract, the invoices, and who demonstrably bore the duty — not customs law, which stops at paying the record importer.
What CBP does not do
CBP does not resolve disputes between an importer of record and its overseas supplier over who keeps a refund.

Why the money goes where it goes

The refund follows the entry record because the entire refund process is built around it. CBP validates that a CAPE filer is the importer of record for the listed entries or the broker who filed them; it pays into the banking details on that ACE account. Nothing in that chain looks at who ultimately funded the duty commercially.

For a seller shipping DDP, the practical consequence is that the party with the legal standing to claim, and the party who actually paid the tariff economically, can be two different companies — and the process pays the first one.

What the question actually turns on

Whether a refund is owed onward is a matter of what was agreed and what can be evidenced. The relevant material is ordinary commercial record-keeping: the terms of sale and any pass-through or duty-adjustment clause; invoices showing how duty was quoted and charged; payment records; and correspondence at the time duties rose.

This is why no honest answer to "can I get it back" is a yes or a no. The facts differ per relationship, and the analysis is legal work.

What Ouli Refund does here, and what it does not

The China-Side Recovery module performs ownership triage — organising which entries are involved, what the documents show about who bore the duty, and what positions the paperwork supports — and prepares correspondence in English with Chinese working notes, plus settlement drafts.

It prepares material for you and your counsel to use. It does not negotiate, does not represent you, and does not promise an outcome. Any demand, settlement or claim is yours and your lawyer's to make.

Where we stand

Software, not legal advice.

Whether a refund is owed to you by your counterparty is a legal question about your contracts, and depends entirely on facts this page cannot see. It calls for your own attorney. Oulution is not a law firm and not a customs brokerage; it prepares documents and analysis, and files nothing.

Oulution is not a law firm and not a customs brokerage. Nothing on this page is legal, customs or tax advice, and no attorney-client relationship is formed by reading it.

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