US tariffs for distributors and wholesalers
The wholesaler is often the importer of record. That is who files, who protests, and who owns a refund if one exists. The foreign seller on DDP terms usually does not.
Working register. Rates on the desk were last checked on 26 August 2026. They are not yet signed off against the governing proclamation or CBP entry practice. Do not treat a rate here as advice to classify, enter, or protest.
Why distribution is an IOR problem first
A distributor who is named as importer of record on the US entry owns classification, payment, protest, and any refund. A Canadian seller who shipped DDP but is not on the entry does not own the claim. The refund follows the IOR, not the flag of the company.
This is the mistake that burns mid-market wholesalers after an IEEPA decision. They paid commercially. They were not on the 7501.
Build the entry list
List every US entry for the last open year. Mark IOR, authority (232, 301, IEEPA, or other), and whether a refund is even possible on that instrument. That list is the exposure. The register tells you which rows can refund and which cannot.
Do not start with a rate table. Start with the entries you actually filed. A rate that is not on your paper is a newspaper number.
What to do this week
Pull ten 7501s. If you cannot, you do not yet have an exposure number. Then run the calculator on the COGS share that sat on those entries, with the rate that was actually paid.
Factual answers
- Can a Canadian distributor claim an IEEPA refund?
- Only if it was the importer of record on the US entry, and only if the duty paid was actually IEEPA. Section 232 is a different file. A court decision on IEEPA does not move a 232 entry.
- Our US customer is the importer. Are we clear?
- You are clear of the filing. You are not clear of the commercial shock. If they come back for a price cut because their duty rose, that is still your margin.
- Should I change Incoterms?
- Incoterms do not override the entry. Changing DDP to FCA without changing who is on the 7501 changes the argument, not the duty. Decide the IOR first.
The register, the calculator, the certificate, the industries, and the mandate sit together. The old standalone calculator is not in this set.
The 7501 is the map
Until the entry list exists, every surcharge is a guess. The desk and the calculator sit on top of that list.