CHINA IEEPA TARIFF REFUND
Your China tariffs
may be refundable.
China was the only country subject to both fentanyl and reciprocal IEEPA tariffs simultaneously — pushing rates to 145% at peak. The Supreme Court ruled all IEEPA tariffs unconstitutional on February 20, 2026. If your entries include HTS 9903.01.20, 9903.01.24, 9903.01.25, or 9903.01.63, the full IEEPA surcharge may be refundable plus interest.
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145%
Peak IEEPA rate on Chinese goods (fentanyl 20% + reciprocal 125%)
$50B+
Estimated total IEEPA duties collected on China-origin imports
4 HTS
Codes: 9903.01.20, .24, .25, .63 — all four refundable
48 Hours
Data submission to capital offer via claim assignment
Two executive orders. Four HTS codes. One unprecedented rate.
Why China Carries the Heaviest IEEPA Burden
China was the only country subject to two simultaneous IEEPA programs: the fentanyl national emergency (EO 14195) and the reciprocal tariff program (EO 14257). The stacking of these programs produced the 145% peak rate on April 9, 2025 — a rate no other trading partner reached. On February 20, 2026, the Supreme Court struck down all IEEPA tariffs in Learning Resources, Inc. v. Trump. The full IEEPA surcharge on Chinese-origin goods — across all four HTS 9903.01 codes — is now eligible for refund plus statutory interest.
Four HTS codes per entry
China entries may contain up to four separate IEEPA HTS codes (9903.01.20, .24, .25, .63) layered on top of Section 301 codes. Separating IEEPA from 301 requires line-level analysis across every affected shipment.
China entries may contain up to four separate IEEPA HTS codes (9903.01.20, .24, .25, .63) layered on top of Section 301 codes. Separating IEEPA from 301 requires line-level analysis across every affected shipment.
China claims dominate the queue
China accounts for the largest share of IEEPA duties collected. When 330,000 importers file into CAPE simultaneously, China claims will comprise the heaviest processing load. Validated filings go first.
China accounts for the largest share of IEEPA duties collected. When 330,000 importers file into CAPE simultaneously, China claims will comprise the heaviest processing load. Validated filings go first.
February 2025 entries nearing deadline
The earliest China fentanyl tariff entries (filed from February 4, 2025) have been liquidating since late 2025. Each entry's 180-day protest window under 19 U.S.C. §1514 is counting down independently.
The earliest China fentanyl tariff entries (filed from February 4, 2025) have been liquidating since late 2025. Each entry's 180-day protest window under 19 U.S.C. §1514 is counting down independently.
Quantify your China IEEPA exposure across all four HTS codes.
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China Rate Timeline
From 10% to 145% in 64 days.
China faced the highest cumulative IEEPA rates of any country. Your refund depends on which rate was in effect when each entry was filed.
| Date | Executive Order | Action | Rate |
|---|---|---|---|
| Feb 4, 2025 | EO 14195 | Fentanyl IEEPA tariff imposed | 10% |
| Mar 4, 2025 | EO 14195 increase | Fentanyl rate doubled | 20% cumulative |
| Apr 2, 2025 | EO 14257 | Reciprocal tariff imposed | 54% |
| Apr 9, 2025 | EO 14257 increase | Reciprocal rate increased | 145% |
| Apr 11, 2025 | Reciprocal pause | Reciprocal portion paused | ~54% |
| Jul 8, 2025 | Rate adjustment | Reciprocal reduction | ~30–54% |
| Feb 20, 2026 | Supreme Court ruling | All IEEPA tariffs unconstitutional | 0% — refund eligible |
HTS Codes
China IEEPA tariff HTS codes.
Look for these codes on your CF-7501 or ES-003 report.
9903.01.20
China fentanyl IEEPA tariff
10% EO 14195 · Feb 4, 2025 9903.01.24
China fentanyl increase
+10% EO 14195 increase · Mar 4, 2025 9903.01.25
China reciprocal IEEPA tariff
34% EO 14257 · Apr 2, 2025 9903.01.63
China reciprocal increase
+91% EO 14257 increase · Apr 9, 2025China Importer Eligibility
If your company imported from China between February 2025 and February 2026, your IEEPA exposure may be substantial.
You are the IOR on Chinese-origin entries
If your company is listed as the importer of record on CF-7501 entry summaries for goods originating from mainland China — filed between February 4, 2025 and February 24, 2026 — you are potentially eligible for a refund of every IEEPA dollar paid.
No minimum China import value
Whether your annual China import volume is $50K or $100M+, the IEEPA refund applies. At rates up to 145%, even modest import volumes produce meaningful recoverable amounts — a $200K China shipment during the April peak could carry $290K in IEEPA duties alone.
Virtually every product category from China
Consumer electronics, toys, apparel, furniture, beauty products, auto parts, industrial machinery, food ingredients, pet products, building materials — if it shipped from China and your entries include any of the four HTS 9903.01 codes, it likely qualifies.
Not sure whether your entries contain China IEEPA HTS codes? That is the first thing our assessment checks.
CHINA RECOVERY PATHS
Four paths to recover duties paid under HTS 9903.01.20/.24/.25/.63.
Your recovery path depends on the liquidation status of each China entry. Because China entries carry the highest per-entry IEEPA amounts, optimizing across paths can materially increase your net recovery.
For unliquidated China entries still open in CBP's ACE system.
A Post-Summary Correction removes HTS 9903.01.20/.24/.25/.63 codes from your China entries before CBP finalizes liquidation. This is the fastest government path — but the window closes at liquidation, which can happen without notice.
Your customs broker files the PSC. We identify which of your China entries are still unliquidated and prioritize them.
Entry Status: Unliquidated China entries
Deadline: Before CBP liquidates the entry
Timeline: Days to weeks once filed
For liquidated China entries within the 180-day protest window.
Filed under 19 U.S.C. §1514 to challenge the IEEPA duty assessment on your China entries. Given that China rates reached 145%, individual protest amounts can be six or seven figures on a single entry.
Your customs broker or trade attorney files the protest. We calculate the exact IEEPA amount per entry and identify which entries are approaching the 180-day cutoff.
Entry Status: Liquidated China entries
Deadline: 180 days from liquidation date
Timeline: 18–36 months for CBP processing
For China entries where the 180-day protest window has closed.
Filed at the Court of International Trade under 28 U.S.C. §1581(i). The two-year statute of limitations runs from the Supreme Court's February 20, 2026 ruling — meaning the deadline is approximately February 20, 2028.
Requires legal representation by a trade attorney admitted to the CIT bar. We refer China importers to qualified counsel.
Entry Status: Finally liquidated China entries
Deadline: ~February 20, 2028 (2-year SOL)
Timeline: 12–24+ months through the court
Convert your China IEEPA claim into capital now.
China claims carry the largest per-entry values in the IEEPA program — which makes them attractive to institutional buyers. Once your ES-003 data is validated and HTS codes mapped, expect a firm non-recourse offer within 48 hours.
No CAPE queue wait. No 18–36 month government timeline. You receive capital now; we assume all recovery and processing risk.
For importers with $500K+ in China IEEPA exposure, deploying capital today often generates more value than waiting for government disbursement.
Entry Status: Any validated China IEEPA claim
Guarantee: 100% Non-Recourse
Timeline: Firm offer within 48 hours of data validation
$24B+
China claims — incomplete or manual
$18B+
China claims — unfiled or pending
$14B+
China claims — standard electronic
$6B+
China claims — validated ES-003 with HTS mapped
CAPE QUEUE POSITION FOR CHINA CLAIMS
China will generate the largest claim volume. Filing order determines who gets paid first.
China imports represent the single largest share of IEEPA duties collected. When CAPE goes live, China claims will dominate the queue. Importers with validated ES-003 data and pre-mapped HTS codes move to the front.
CBP Declaration, Atmus Filtration Inc. v. United States, March 19, 2026
45 days from March 11, 2026 — per CBP court filing. China claims expected to account for the largest share of CAPE processing volume.
45 days from March 11, 2026 — per CBP court filing. China claims expected to account for the largest share of CAPE processing volume.
Three steps from entry data to recovery path.
01
Share your China entry data.
Export your ES-003 Entry Summary Details from CBP's ACE portal. We isolate entries tagged with HTS 9903.01.20 (fentanyl 10%), 9903.01.24 (fentanyl increase to 20%), 9903.01.25 (reciprocal 34%), and 9903.01.63 (reciprocal increase to 145%).
02
We quantify your China-specific exposure.
Each China entry is mapped against the rate that was in effect on its filing date — from 10% in early February 2025 to 145% in the April 9–11 peak window. We calculate your aggregate refund including statutory interest and flag entries nearing their 180-day protest deadline.
03
You select your recovery strategy.
We present your four options with China-specific projections: PSC for unliquidated entries, formal protest for recently liquidated entries, CIT litigation for entries past the 180-day window, or immediate capital via claim assignment in 48 hours.
CHINA-FOCUSED RECOVERY
The dedicated resource for China IEEPA tariff refunds.
This site addresses the specific challenges China importers face: dual-program tariff stacking, Section 301 overlap, four distinct HTS codes, and the largest per-entry exposure in the IEEPA program. For assessment across all origin countries, visit tariffresolution.com. To convert a validated China claim into immediate capital, visit tariffbuyouts.com.
All-Country Assessment Tariff Resolution IEEPA recovery for China, Canada, Mexico, and all affected origins Eligibility Check Tariff Refund Checker Answer 5 questions to determine if your China IEEPA entries qualify for a refund Sell Your China Claim Tariff Buyouts Convert your validated China IEEPA claim into immediate capital
Get your all-country assessment → Start Your China Claim
Calculate your China IEEPA tariff exposure.
Share your company and China import details. We isolate entries tagged with HTS 9903.01.20/.24/.25/.63, calculate your aggregate exposure across the full rate timeline (10% to 145%), and present your recovery options — at no cost and with no obligation.
Our China-specific assessment covers all four HTS codes (9903.01.20/.24/.25/.63), maps every rate change from February 2025 through February 2026, and delivers your estimated refund within 5–10 business days.
Mutual NDA on all China import data
China trade specialist responds within 48 hours
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CHINA-SPECIFIC FAQ
China tariff refund questions.
Our China-specific assessment isolates entries across all four IEEPA HTS codes, separates IEEPA from Section 301 exposure, and maps each entry to the optimal recovery path. If your situation requires formal protest filing or CIT litigation, we refer you to qualified trade counsel.
Get My China Assessment → China data preparation guide → China rate timeline → Why are China IEEPA refunds larger than other countries?
China was the only country subject to both fentanyl IEEPA tariffs (EO 14195, 20% cumulative) and reciprocal IEEPA tariffs (EO 14257, up to 125%) simultaneously. The stacking produced a 145% peak rate — more than seven times the 20% baseline most other countries faced. Additionally, thousands of Chinese products carried zero pre-IEEPA duty, meaning the full IEEPA surcharge is recoverable.
Which four HTS codes cover China IEEPA tariffs?
9903.01.20 (fentanyl tariff at 10%, effective Feb 4, 2025), 9903.01.24 (fentanyl increase to 20% cumulative, effective Mar 4, 2025), 9903.01.25 (reciprocal tariff at 34%, effective Apr 2, 2025), and 9903.01.63 (reciprocal increase to 125%, effective Apr 9, 2025). All four are covered by the Supreme Court ruling.
How does the fentanyl tariff differ from the reciprocal tariff on China?
The fentanyl tariff (EO 14195) targeted China specifically for fentanyl trafficking, starting at 10% and rising to 20%. The reciprocal tariff (EO 14257) was part of the broader Liberation Day program affecting many countries — but China received the highest reciprocal rate at 125%. Both programs stacked on Chinese goods, producing the 145% combined peak.
Are Section 301 tariffs on China also refundable?
No. Section 301 tariffs (HTS 9903.88.xx) were imposed under different legal authority starting in 2018 and remain in effect. The Supreme Court's February 2026 ruling applies exclusively to IEEPA tariffs (HTS 9903.01.xx). Section 301 challenges are proceeding through separate litigation in the Court of International Trade.
I import from China through Hong Kong or Taiwan. Do those entries qualify?
IEEPA tariffs apply based on country of origin, not port of shipment. If the goods originate from mainland China (as declared on the CF-7501), they are subject to China IEEPA tariffs regardless of transshipment through Hong Kong, Taiwan, Vietnam, or other intermediaries. Your entry data will show the declared country of origin.
My China products were duty-free before IEEPA. Is the entire surcharge recoverable?
In most cases, yes. Products that carried 0% normal duty before IEEPA had no baseline tariff — the IEEPA rate was the only duty collected. When that rate is ruled unconstitutional, the full amount may be refundable. This is why consumer electronics, toys, furniture, and beauty products from China have near-100% recovery ratios. Check your eligibility →
Can Amazon sellers and ecommerce importers from China get a refund?
If your company is listed as the importer of record on the CF-7501 entry summary, you may qualify. Many Amazon FBA sellers and DTC brands who source directly from China through a customs broker are the IOR. If a 3PL or fulfillment company imported under their own name, the refund belongs to them. See our ecommerce guide for details.
What is the timeline for receiving a China tariff refund?
CBP's CAPE system targets mid-April 2026 for launch, with full processing estimated at 18–36 months. China claims are expected to represent the largest share of filing volume. For importers who need capital sooner, claim assignment delivers non-recourse payment in 48 hours.