If you sell on Amazon and source products from China, you likely paid IEEPA tariffs at rates up to 145% between February 2025 and February 2026 — and those tariffs are now refundable. The key question is whether you are the importer of record on your customs entries. Your selling model (FBA, FBM, Vendor Central, or hybrid) determines eligibility. For a full overview of ecommerce seller eligibility, see the ecommerce guide.
How IOR status works across Amazon models
The importer of record (IOR) is the entity legally responsible for paying customs duties. Only the IOR can claim a refund. Which Amazon model you use determines who holds IOR status.
Fulfilled by Amazon (FBA) — private label. You source products from a Chinese manufacturer, ship them to an Amazon fulfillment center, and sell under your own brand. In this model, you or your company are almost certainly the IOR. Your customs broker filed entry summaries (CF-7501) with your company name in the IOR field. You paid the duties. You qualify.
Fulfilled by Merchant (FBM) — direct import. You import inventory to your own warehouse and ship orders yourself. Same as FBA private label: you are the IOR if you arranged the import. You qualify.
Retail arbitrage / wholesale. You buy products from U.S. wholesalers or retailers and resell on Amazon. You are NOT the IOR. The original importer — the wholesaler who brought the goods into the country — is the IOR. The IEEPA tariff was embedded in the price you paid, but you cannot file the refund claim. Only the entity on the CF-7501 can.
Amazon Vendor Central. Amazon issues purchase orders, and you ship goods to Amazon’s distribution centers. If Amazon arranges the international freight and clears customs, Amazon is the IOR. If you import the goods into the U.S. and then sell domestically to Amazon, you are the IOR. Check your purchase order terms — the Incoterm (DDP vs. FOB) usually determines who holds IOR responsibility.
3PL-managed imports. Some sellers use third-party logistics providers who handle customs clearance. The 3PL may have filed entries under your company name (you are IOR) or under their own import bond (they are IOR). Ask your 3PL directly: “Whose name appears as importer of record on the CF-7501?”
How to verify your IOR status
Step 1: Contact your customs broker. Ask specifically: “Am I listed as the importer of record on my entry summaries for China imports between February 2025 and February 2026?” This is a routine question — brokers answer it daily.
Step 2: Request your CF-7501 entry summaries. Your company name, address, and IOR number should appear in Block 21 (Importer of Record) of the CF-7501. If your company name is there, you are the IOR.
Step 3: Pull your ES-003 report. The Entry Summary Report (ES-003) from the ACE Secure Data Portal lists every entry filed under your IOR number. Request the full covered period — February 4, 2025 through February 24, 2026. This report shows every IEEPA duty you paid and is the basis for calculating your refund.
Step 4: Check for IEEPA-specific HTS codes. Your entries should show one or more of these codes: 9903.01.20 (fentanyl 10%), 9903.01.24 (fentanyl additional 10%), 9903.01.25 (reciprocal 34%), or 9903.01.63 (reciprocal additional 91%). These are the refundable IEEPA line items. For the full rate history by date, see the IEEPA rate timeline.
Dollar-amount examples for FBA sellers
The refund calculation is straightforward: IEEPA duty paid = refundable amount, plus applicable interest.
Small FBA seller. Annual China imports: $150,000. Average IEEPA rate during covered period: 30%. IEEPA duties paid: $45,000. Estimated refund: $45,000 plus interest accrued from the date of payment.
Mid-size FBA seller. Annual China imports: $500,000. Average IEEPA rate: 40% (higher average due to entries during peak periods). IEEPA duties paid: $200,000. Estimated refund: $200,000 plus interest.
Large private-label brand on Amazon. Annual China imports: $2,000,000. Average IEEPA rate: 35%. IEEPA duties paid: $700,000. Estimated refund: $700,000 plus interest. At this level, the refund often exceeds the seller’s annual net profit from the Amazon business.
Many FBA products from China had zero pre-IEEPA duty rates. Consumer electronics accessories (HTS Chapter 85), plastic housewares (Chapter 39), and toys (Chapter 95) commonly entered duty-free. For these categories, the entire IEEPA surcharge is the refundable amount — there is no underlying MFN duty to subtract. Use tariffrefundchecker.com for a quick estimate based on your import volume.
What to do now
- Confirm your IOR status using the steps above. This takes one email or phone call to your customs broker.
- Request your ES-003 for the full covered period. Your broker can pull this in 24–48 hours.
- Separate IEEPA from Section 301. If you imported from China, your entries likely carry both. Only IEEPA (HTS 9903.01.xx) is refundable now. See the Section 301 vs. IEEPA explainer for details on which codes are refundable, and the documentation guide for required records.
- Get a free assessment. The assessment calculates your exact refundable amount based on your actual entries — not estimates.
- Decide between CAPE filing and immediate recovery. CBP’s CAPE portal processes refunds on a government timeline. Claim assignment through firms like tariffresolution.com delivers capital in 48 hours. Customs brokers and freight forwarders in the Tariff Partners program can also facilitate the filing process on your behalf.
FAQ
Q: I use Amazon FBA and import from China through a freight forwarder. Am I the IOR? A: In most cases, yes. Freight forwarders arrange logistics but typically file customs entries under your company name and import bond. Confirm by checking the IOR field on your CF-7501 entry summaries or asking your forwarder directly.
Q: Can I claim a refund on products I already sold on Amazon? A: Yes. The refund is based on the duties you paid at the time of import, not on the downstream sale. Whether you sold the products, still hold inventory, or even disposed of them is irrelevant to the refund claim.
Q: My Amazon business closed in 2025 but I imported from China during the IEEPA period. Can I still claim? A: Yes. The claim belongs to the entity that was the IOR at the time of entry. Even if the business is no longer active on Amazon, the legal entity that paid the duties can still file for a refund or assign the claim.