IEEPA tariffs on Chinese imports escalated from 10% in February 2025 to 145% at peak in April 2025, before being partially reduced and ultimately eliminated. All rates were set to zero on February 20, 2026, when the Supreme Court ruled the entire IEEPA tariff regime unconstitutional in Learning Resources v. Trump. Your refund amount depends on which rate was in effect when each of your entries was filed. For a full breakdown of current and historical rates, see the rate reference page.
February 4, 2025 — 10%
Executive Order 14195 imposed a 10% fentanyl tariff on all Chinese-origin goods under HTS 9903.01.20. This was the first IEEPA tariff ever imposed on a trading partner. It applied to every product from China regardless of category, HTS classification, or value.
The legal basis was the International Emergency Economic Powers Act, which grants the president authority to regulate commerce during a declared national emergency. The administration cited fentanyl precursor chemical flows from China as the emergency. No prior IEEPA invocation had targeted broad merchandise imports. The trade community was largely caught off guard — most importers had no systems in place to track IEEPA-specific duties separate from existing Section 301 or MFN obligations.
At 10%, the initial impact was manageable for most importers. High-volume consumer electronics and toy importers absorbed the cost or passed it through. But the precedent it set — unilateral tariff authority without congressional approval — would prove far more consequential than the rate itself.
March 4, 2025 — 20% cumulative
The fentanyl rate doubled exactly one month later. HTS 9903.01.24 covered the additional 10 percentage points. Total IEEPA burden: 20% on every China import, stacked on top of any existing MFN duties and Section 301 tariffs.
Between February 4 and March 4, importers scrambled to accelerate shipments. Those who got goods through customs before March 4 locked in the 10% rate. Those who did not faced double the exposure. This one-month window illustrates why entry-level filing date analysis matters — a single day’s difference on a $500,000 shipment means $50,000 more or less in refundable duties.
April 2, 2025 — 54% cumulative
Executive Order 14257 introduced an entirely separate IEEPA tariff program: reciprocal tariffs. China’s reciprocal rate was 34% under HTS 9903.01.25, layered on top of the existing 20% fentanyl tariff. Total IEEPA burden: 54%.
This was already the highest IEEPA rate imposed on any country. For context, the next-highest reciprocal rate was 46% on Vietnam. China carried that 46%-equivalent reciprocal rate plus 20% in fentanyl tariffs that no other country faced.
The commercial impact was severe. Products that entered the U.S. duty-free before February 2025 now carried a 54% surcharge overnight. A $100,000 shipment of consumer electronics that previously cleared customs at $0 in duty now owed $54,000 in IEEPA tariffs alone. Many importers halted China orders entirely or began emergency sourcing shifts to Vietnam and India.
April 9, 2025 — 145% cumulative
Seven days after the reciprocal tariff launched, the administration escalated China’s reciprocal rate to 125%, adding HTS 9903.01.63 (the additional 91 percentage points). Total IEEPA burden: 20% fentanyl + 125% reciprocal = 145%.
This was the absolute peak. Any entries filed between April 9 and April 11 carry the highest per-entry exposure in the entire IEEPA program. A $200,000 shipment filed on April 10 generated $290,000 in IEEPA duties — more than the value of the goods themselves. These entries represent the single highest-value refund claims in the entire recovery program.
The 145% rate made most China imports commercially nonviable. Customs brokers reported that many importers refused to accept delivery, leaving containers at port. Others filed entries under protest, anticipating litigation. The Supreme Court case that ultimately struck down the entire program, Learning Resources v. Trump, was filed during this period.
April 11, 2025 — ~54% cumulative
The 125% reciprocal rate was paused after just 48 hours. China’s effective rate returned to approximately 54% — the 20% fentanyl tariff plus the original 34% reciprocal rate.
The April 9–11 window was the briefest rate period in the entire timeline, but entries filed during it have enormous exposure. If you imported during those 48 hours, each entry may represent the largest individual refund claim in your portfolio. A professional assessment identifies these high-value entries automatically.
July 8, 2025 — ~30–54% (varies)
Further executive adjustments brought China’s effective IEEPA rate to approximately 30–54% depending on product classification and the specific combination of fentanyl and reciprocal provisions in effect. Some product categories received temporary exclusions that reduced the effective rate. Others maintained the full stack.
This period — July 2025 through February 2026 — represents the longest sustained rate window and likely the highest total import volume at IEEPA rates. Most importers who continued sourcing from China during this period did so at these rates. The aggregate refund exposure across this window dwarfs any single peak-rate period simply because of volume.
February 20, 2026 — 0%
The Supreme Court ruled all IEEPA tariffs unconstitutional. Every rate during the entire covered period — from 10% to 145% — is now refundable. The ruling applied to all IEEPA tariffs, not just those on China, but China importers hold the majority of total exposure because of the stacked fentanyl and reciprocal programs.
CBP began processing refunds through the CAPE portal system. Importers can also pursue immediate recovery through claim assignment programs offered by firms like tariffresolution.com and tariffbuyouts.com. Licensed customs brokers and trade attorneys can file on your behalf through the Tariff Partners program.
How rate timing affects your refund
Your refund is calculated entry by entry. Each customs entry carries the IEEPA rate in effect on its filing date. Two shipments of identical goods, one week apart, can have dramatically different refund values if a rate change fell between them.
Consider a mid-size importer who brought in $5 million from China between February 2025 and February 2026. If $1 million cleared at 10%, $2 million at 54%, and $2 million at 30%, the total IEEPA exposure is $1.78 million — not a single flat percentage applied to the total.
This is why entry-level analysis matters. Averaged estimates understate some claims and overstate others. A proper assessment matches each entry to its exact rate and calculates the precise refundable amount.
FAQ
Q: Are all IEEPA rates from the entire February 2025 to February 2026 period refundable? A: Yes. The Supreme Court ruling applied retroactively to the entire period. Every IEEPA tariff paid on Chinese imports — at any rate from 10% to 145% — is eligible for refund. Check your specific exposure with a free assessment.
Q: Do entries filed during the 48-hour 145% window on April 9–11 receive the full 145% refund? A: Yes. The refund matches the rate in effect at the time of filing. Entries filed during the 145% peak are refundable at 145% of the dutiable value attributable to IEEPA. These are the highest-value individual entries in the program.
Q: How do I determine which rate applied to each of my entries? A: Your customs broker can pull your ES-003 report from the ACE portal, which shows every entry with its HTS codes and duty amounts. Each IEEPA HTS code (9903.01.20, 9903.01.24, 9903.01.25, 9903.01.63) corresponds to a specific rate and date range.