Products from China that were duty-free or low-duty before IEEPA have the highest recovery potential — the entire IEEPA surcharge represents the full refundable amount with no underlying MFN duty to subtract. Categories with high import volumes and zero pre-IEEPA rates generate the largest claims. Below are the ten categories ranked by recovery ratio and aggregate exposure. For industry-specific guidance, see the industry breakdown page.
1. Consumer Electronics (HTS Chapters 84, 85)
Pre-IEEPA MFN rate: 0–3% on most products. Smartphones, laptops, tablets, monitors, and peripherals entered duty-free under the Information Technology Agreement. IEEPA rate applied: Up to 145% at peak, stabilized at 30–54% for most of the covered period. Recovery ratio: Near 100% of IEEPA duties paid. Almost no underlying MFN duty offsets the claim.
Consumer electronics represent the single largest category of U.S. imports from China by value. Even a mid-size electronics importer bringing in $5 million annually faced $1.5–2.7 million in IEEPA duties.
2. Toys and Games (HTS Chapter 95)
Pre-IEEPA MFN rate: 0%. Toys have entered the U.S. duty-free for decades. IEEPA rate applied: Up to 145%. Recovery ratio: 100% of IEEPA duties paid. Over 80% of U.S. toys are manufactured in China.
Learning Resources — the company that brought the Supreme Court case Learning Resources v. Trump — is a toy company. The toy industry’s existential exposure to IEEPA tariffs drove the litigation that ultimately struck down the entire program. A toy importer bringing in $10 million annually at a 40% average IEEPA rate has $4 million in refundable duties.
3. Furniture and Home Goods (HTS Chapters 44, 69, 83, 94)
Pre-IEEPA MFN rate: 0% on most categories. Wooden furniture (Chapter 44), ceramic decorative articles (Chapter 69), base metal hardware (Chapter 83), and lamps/lighting (Chapter 94) were largely duty-free. IEEPA rate applied: Up to 145%. Recovery ratio: Near 100% on duty-free subcategories. Some furniture items carried 0–5% MFN rates, slightly reducing the recovery ratio.
This category includes home decor, kitchenware, storage solutions, lighting fixtures, and small furniture. DTC home brands and major retailers alike sourced heavily from China. The combination of high volume and zero pre-IEEPA duties makes this category one of the highest-exposure segments. See our ecommerce guide for DTC-specific details.
4. Beauty and Cosmetics (HTS Chapter 33)
Pre-IEEPA MFN rate: 0% on most finished cosmetics and skincare products. IEEPA rate applied: Up to 145%. Recovery ratio: Near 100%. Skincare formulations, fragrances, hair care products, and cosmetic tools all entered duty-free.
The beauty industry’s China dependence extends beyond finished products to packaging components (HTS 3923, also 0% MFN) and applicator tools. A mid-size beauty brand importing $800,000 annually from China at 35% average IEEPA rate has approximately $280,000 in refundable exposure.
5. Apparel and Textiles (HTS Chapters 61, 62)
Pre-IEEPA MFN rate: 12–32% depending on fiber content and construction. Knit garments (Chapter 61) and woven garments (Chapter 62) carry some of the highest MFN rates in the tariff schedule. IEEPA rate applied: Up to 145% stacked on top of MFN. Combined rate at peak: Exceeded 170% on some items. Recovery ratio: IEEPA portion only. The underlying MFN duty is not refundable.
Apparel is high volume but lower recovery ratio per dollar compared to duty-free categories. A $1 million apparel import at 25% MFN + 40% IEEPA = $650,000 total duty. The $400,000 IEEPA portion is refundable; the $250,000 MFN portion is not. Still substantial — but the percentage recovery is lower than duty-free categories.
6. Pet Products (HTS Chapters 42, 63, 73, 94)
Pre-IEEPA MFN rate: 0% on most pet accessories — beds, bowls, leashes, crates, toys. IEEPA rate applied: Up to 145%. Recovery ratio: 100% on most items.
Pet products are among the fastest-growing import categories from China, with China as the dominant manufacturing base for non-food pet products. Full IEEPA recovery applies to nearly every subcategory. Both the fentanyl and reciprocal IEEPA programs apply — see the fentanyl vs. reciprocal breakdown for how the two programs stack on each entry.
7. Footwear (HTS Chapter 64)
Pre-IEEPA MFN rate: 6–48% depending on material, construction, and gender classification. Rubber/plastic footwear faces rates up to 48%; leather footwear is typically 8–20%. IEEPA rate applied: Up to 145% stacked on top. Combined rate at peak: Exceeded 190% on some rubber footwear. Recovery ratio: IEEPA portion only.
Footwear is structurally similar to apparel — high underlying MFN rates mean the total duty burden was extreme, but only the IEEPA layer is refundable. A footwear importer paying 37% MFN + 40% IEEPA on a $2 million annual import program has $800,000 in IEEPA exposure.
8. Auto Parts (HTS Chapter 87)
Pre-IEEPA MFN rate: 0–6% on most components. Brake pads, filters, lighting, and aftermarket accessories. IEEPA rate applied: Up to 145%. Recovery ratio: 90–100% depending on specific HTS classification.
Auto parts carry high per-unit values. A single container of brake rotors or engine components can be worth $200,000+. At 40% IEEPA, that is $80,000 in refundable duties per container. Importers who bring in multiple containers per month accumulated massive exposure over the 12-month covered period.
9. Building Materials (HTS Chapters 25, 68, 69, 73)
Pre-IEEPA MFN rate: 0% on most products. Ceramic tile (Chapter 69), cut stone (Chapter 68), steel hardware (Chapter 73), and basic mineral products (Chapter 25) were largely duty-free. IEEPA rate applied: Up to 145%. Recovery ratio: Near 100%.
Building material importers often operate on thin margins — 8–15% gross margins are typical. A 30–54% IEEPA surcharge made many China-sourced materials noncompetitive against domestic or alternative-origin products. The refund restores over a year of compressed margins.
10. Vitamins and Supplements (HTS Chapters 21, 29)
Pre-IEEPA MFN rate: Low to zero on most formulations and raw ingredients. IEEPA rate applied: Up to 145%. Recovery ratio: Near 100%.
China is the dominant global source for raw supplement ingredients — ascorbic acid (Vitamin C), amino acids, herbal extracts, and mineral compounds. U.S. supplement brands that import finished products or bulk ingredients accumulated significant IEEPA exposure.
How to determine your category exposure
Your ES-003 report from the ACE portal lists every entry with its HTS codes. The first two digits of each HTS code identify the chapter and product category. Match your entries to the categories above to estimate your recovery ratio. A free assessment performs this analysis automatically and calculates your precise refundable amount, including interest. For a quick estimate, use the eligibility screener at tariffrefundchecker.com. Importers who need immediate capital can explore non-recourse claim acquisition through tariffbuyouts.com. For the full rate history, see the China IEEPA rate timeline.
FAQ
Q: My products span multiple categories. How do I calculate total exposure? A: Each entry is calculated independently based on its HTS classification. If you import electronics (0% MFN, near-100% recovery) and apparel (25% MFN, IEEPA-only recovery), each entry’s refund is calculated at its own rate. A professional assessment handles multi-category portfolios automatically.
Q: Are there any product categories excluded from IEEPA refunds? A: No. The Supreme Court ruling struck down all IEEPA tariffs on all products from all countries. There are no product-level exclusions from the refund program. Every HTS code that carried an IEEPA surcharge (9903.01.xx) is refundable.
Q: Do products that also carry Section 301 tariffs get a reduced IEEPA refund? A: No. The IEEPA refund is calculated solely on the IEEPA duty amount paid. Section 301 tariffs are a separate line item on your entry summary and do not reduce or offset the IEEPA refund. You recover the full IEEPA amount regardless of what other tariffs applied to the same goods.