China tariff refund: common questions.
Are China tariffs being refunded?
Yes. The Supreme Court ruled on February 20, 2026 that IEEPA tariffs on China (and all other affected countries) were unconstitutional. Importers of record who paid these duties may be eligible for a refund. CBP is building the CAPE system to process refunds. Check your eligibility →
What is the difference between IEEPA tariffs and Section 301 tariffs on China?
IEEPA tariffs (HTS 9903.01.xx) were imposed via executive order under IEEPA starting February 2025. The Supreme Court ruled these unconstitutional. Section 301 tariffs (HTS 9903.88.xx) were imposed under different legal authority starting in 2018. Section 301 tariffs are NOT covered by this ruling. See the documentation guide for full HTS code details.
I pay both IEEPA and Section 301 tariffs. Which is refundable?
Only the IEEPA portion (HTS 9903.01.xx). Section 301 tariffs (HTS 9903.88.xx) are separate. A detailed Impact Assessment separates them and calculates only the IEEPA exposure. For multi-country IEEPA assessment beyond China, visit tariffresolution.com →
What was the highest IEEPA rate on China?
145%, effective during the April 9–11, 2025 window. This combined the 20% fentanyl tariff with a 125% reciprocal tariff. See the full rate timeline for every China IEEPA rate change.
What HTS codes apply to China IEEPA tariffs?
9903.01.20 (fentanyl 10%), 9903.01.24 (fentanyl increase), 9903.01.25 (reciprocal 34%), and 9903.01.63 (reciprocal increase). Your customs broker can pull entries under these codes from the ACE portal — see our documentation guide.
When will I receive my China tariff refund?
CBP’s CAPE system targets mid-April 2026 for launch. Full processing may take 18–36 months. Immediate capital delivers payment in 48 hours for importers who cannot wait.
Can I sell my China tariff refund claim?
Yes. Institutional buyers acquire validated claims for immediate, non-recourse payment — typically within 48 hours. tariffbuyouts.com →
Is the China fentanyl tariff refundable?
Yes. The fentanyl tariff (EO 14195, HTS 9903.01.20 and 9903.01.24) was imposed under IEEPA and is included in the ruling.
I import from China through Hong Kong. Does it count?
IEEPA tariffs are based on country of origin, not country of shipment. If the goods originate from mainland China, they are subject to IEEPA tariffs regardless of transshipment.
My products had zero duty before IEEPA. Is the full amount refundable?
In many cases, yes. If a product was duty-free before IEEPA, the estimated full IEEPA amount may be refundable.
How do I start?
Request a free Impact Assessment. Provide your ES-003 entry data and we calculate your China-specific IEEPA exposure.