IEEPA Reciprocal Tariffs: Which Countries Were Affected and What's Refundable

In April 2025, the Trump administration dramatically expanded the IEEPA tariff program beyond Canada, Mexico, and China by issuing a “reciprocal tariff” executive order targeting roughly 180 trading partners simultaneously. These IEEPA reciprocal tariffs hit importers from the European Union, Japan, Vietnam, South Korea, India, Taiwan, and dozens of other countries with rates ranging from 10% to 49%.

Because these reciprocal tariffs were imposed under IEEPA authority — the same authority the Supreme Court struck down in February 2026 — they are fully eligible for refund through the CAPE portal, just like the Canada/Mexico and China IEEPA tariffs.

This guide explains how the IEEPA reciprocal tariffs worked, which countries were affected, what rates applied, and how to identify and claim your refund.

What Were the IEEPA Reciprocal Tariffs?

The “reciprocal tariff” executive order, signed in April 2025, directed the U.S. Trade Representative (USTR) to calculate an individual tariff rate for each of the United States’ trading partners based on an assessment of that country’s tariff rates on U.S. goods and non-tariff trade barriers (such as subsidies, regulatory barriers, and currency policies).

The stated rationale was to “level the playing field” — hence the term “reciprocal.” In practice, the rates were set formulaically and applied broadly to all goods from each country, regardless of whether the specific product was subject to the foreign country’s trade barriers.

The key legal mechanism was the same as for Canada, Mexico, and China: IEEPA authority, justified by a national emergency declaration. This is why the Supreme Court’s ruling in Learning Resources, Inc. v. Trump — which invalidated IEEPA tariff authority entirely — also applies to the reciprocal tariffs.

Which Countries Were Affected?

The reciprocal tariff order covered essentially all U.S. trading partners, though rates varied widely. The following table lists the major trading partners and their assigned rates:

Country / Region	IEEPA Reciprocal Rate	HTS Code Range
European Union	~20%	9903.01.21
United Kingdom	10%	9903.01.22
Japan	24%	9903.01.26
South Korea	25%	9903.01.28
Taiwan	32%	9903.01.29
India	26%	9903.01.27
Vietnam	46%	9903.01.25
Thailand	36%	9903.01.30
Cambodia	49%	9903.01.31
Bangladesh	37%	9903.01.32
Indonesia	32%	9903.01.33
Malaysia	24%	9903.01.34
Switzerland	31%	Varies
Australia	10%	Varies
Brazil	10%	Varies

Rates are approximate. Verify against CBP Federal Register notices for each executive order. Rates were modified for some countries during the April–December 2025 period.

Note on China: China was not included in the April reciprocal tariff order because China-specific IEEPA tariffs were already escalating under a separate executive order (reaching 125% by June 2025). The reciprocal order applied to all other countries.

Why Vietnam, Cambodia, and Bangladesh Were Particularly Affected

Many U.S. importers had shifted production from China to Vietnam, Cambodia, and Bangladesh during 2018–2024 to avoid Section 301 tariffs imposed during the first Trump administration. These countries became major alternative sourcing hubs for apparel, footwear, electronics accessories, and consumer goods.

The April 2025 IEEPA reciprocal tariffs hit these alternative sourcing countries with some of the highest rates in the program:

• Vietnam: 46%
• Cambodia: 49%
• Bangladesh: 37%

Importers who had already paid China IEEPA tariffs before shifting production were effectively taxed twice — first on their China-sourced goods, then on their alternative-source goods. Both sets of IEEPA payments are refundable under the CAPE program.

Which Imports From These Countries Qualify?

The reciprocal tariffs applied broadly to all goods from affected countries, with limited exclusions for certain products (primarily pharmaceuticals and some agricultural goods). For importers from reciprocal tariff countries, the qualifying criteria are the same as for all IEEPA refunds:

1. Entry date: Goods must have entered the U.S. after the reciprocal tariff executive order’s effective date (mid-April 2025) and before February 20, 2026 (the Supreme Court ruling date)
2. IEEPA codes present: Your CBP Form 7501 must show a 9903.01.xx Chapter 99 code for the reciprocal rate applied
3. You are the Importer of Record: Box 26 of Form 7501 shows your EIN or CBP importer number
4. Entry within Phase 1 scope: Unliquidated or liquidated within the past 80 days

How to Identify Reciprocal Tariff Entries in Your Records

Reciprocal tariff entries look different from Canada/Mexico or China entries because the 9903.01.xx suffix is country-specific. If you imported from Vietnam, the code would be 9903.01.25; from Japan, 9903.01.26; and so on.

To find your reciprocal tariff entries:

1. In ACE: Filter your entry records by date range (April 2025 – February 2026) and look for entries with 9903.01.xx Chapter 99 codes where the final two digits correspond to the reciprocal country code
2. On Form 7501: Check the “Classification” section of each entry summary for secondary Chapter 99 codes
3. From your broker: Request a report of all entries that included HTS Chapter 99 9903.01.xx codes during the IEEPA period

Our IEEPA tariff codes guide has a full reference table of codes by country.

Reciprocal Tariffs vs. Other IEEPA Tariffs: Key Differences

While all IEEPA tariffs are refundable through CAPE, the reciprocal tariffs have some unique characteristics importers should understand:

Rate modifications: The reciprocal tariff rates were modified more frequently than the Canada/Mexico rates. Some countries received temporary rate reductions or pauses during 2025 as bilateral negotiations proceeded. Your actual duty exposure depends on the specific rate in effect on each entry date.

Country-specific codes: Each reciprocal tariff country has its own HTS code, making it essential to match the correct code to the correct country on your CAPE CSV.

No Section 301 overlap (for non-China countries): Unlike China, where Section 301 and IEEPA tariffs stacked on top of each other, most reciprocal tariff countries only had the IEEPA surcharge. This means the IEEPA refund represents the full amount of the extraordinary tariff burden — there is no non-refundable Section 301 component.

USMCA interaction (for non-Canada/Mexico countries): The reciprocal tariffs did not generally interact with preferential trade agreements the way the Canada/Mexico tariffs interacted with USMCA. However, goods from countries with other U.S. bilateral trade agreements (e.g., Australia, South Korea’s KORUS FTA) may have complex eligibility situations depending on how the executive orders handled those agreements.

Industries Most Affected by Reciprocal Tariffs

Apparel and textiles: Bangladesh (37%), Vietnam (46%), and Cambodia (49%) are among the largest apparel exporters to the U.S. Clothing and footwear importers with Southeast Asian supply chains were among the hardest hit.

Electronics accessories: Vietnam and Taiwan are major suppliers of electronics components and finished devices. The 46% Vietnam rate and 32% Taiwan rate created substantial duty burdens on phone accessories, cables, computer peripherals, and components.

Furniture: Vietnam is a leading U.S. furniture supplier. The 46% IEEPA rate on Vietnamese furniture, stacked on any existing furniture tariffs, created significant cost pressures for furniture importers.

Industrial equipment and machinery: Japan and Germany (EU) are major suppliers of precision machinery, tools, and industrial equipment. The 24% Japan rate and ~20% EU rate affected importers of capital equipment who had sourced from these countries to avoid China supply chain risks.

Consumer goods: Malaysia (24%) and Indonesia (32%) supply a range of consumer goods. Importers who had diversified sourcing to these countries also faced IEEPA reciprocal tariffs.

Estimating Your Reciprocal Tariff Refund

To estimate your potential refund from reciprocal tariff entries:

1. Pull your entry records for April 2025 through February 2026 from ACE or your broker
2. Identify entries with 9903.01.xx codes (excluding 9903.01.01-.03 which are Canada/Mexico, and 9903.01.10-.14 which are China)
3. Sum the IEEPA duty amounts on those entries
4. Add statutory interest (accruing from each entry’s original duty payment date)

For a detailed walkthrough of the CAPE filing process, see our CAPE portal guide. For help determining whether to self-file or use a recovery specialist, see our DIY vs. expert help guide.

Key Takeaways

• The IEEPA reciprocal tariffs, imposed in April 2025, targeted approximately 180 countries with rates of 10–49%
• These tariffs are fully refundable under the CAPE program — the Supreme Court’s ruling covers all IEEPA tariffs regardless of which country was targeted
• Vietnam (46%), Cambodia (49%), and Bangladesh (37%) faced the highest rates; importers who shifted sourcing from China to these countries paid IEEPA tariffs on both their original Chinese goods and their alternative sources
• Reciprocal tariff entries are identified by HTS Chapter 99 codes in the 9903.01.2x–9903.01.3x range
• The same Phase 1 eligibility requirements apply: entries must be unliquidated or liquidated within the past 80 days

Check your eligibility or connect with a recovery specialist to review your specific entries.