When Did the IEEPA Tariffs Start? A Complete Timeline

Understanding when specific IEEPA tariffs went into effect is essential for determining which of your import entries may be eligible for a CAPE refund. This guide provides a complete timeline of IEEPA tariff start dates — and explains how the timing of entry filing and liquidation affects Phase 1 eligibility.

Why the Start Date Matters

IEEPA tariffs were imposed through a series of executive orders, each with its own effective date. Goods that entered U.S. customs before an executive order’s effective date were not subject to that order’s tariffs — only entries on or after the effective date are covered.

For CAPE refund purposes, this means:

1. Entries dated before the relevant executive order’s effective date are not eligible
2. Entries dated on or after the effective date and before the Supreme Court ruling on February 20, 2026 are eligible (subject to Phase 1 liquidation status requirements)
3. For Phase 1 specifically, eligible entries must also be either unliquidated or liquidated within the 80-day window before your filing date

Complete Chronological Timeline of IEEPA Tariff Start Dates

February 4, 2025 — Canada and Mexico Tariffs Begin

President Trump signed executive orders imposing IEEPA tariffs on Canada and Mexico simultaneously.

• Canada (general goods): 25% effective February 4, 2025
• Canada (energy and potash): 10% effective February 4, 2025
• Mexico (all goods): 25% effective February 4, 2025

This was the first-ever use of IEEPA for tariff imposition in the law’s 48-year history. Goods that entered U.S. customs on or after this date from Canada or Mexico may carry IEEPA codes on Form 7501.

Exception: Goods that were in transit (already on the water) as of February 4 may have received a brief grace period depending on CBP’s entry date rules. Check with your customs broker for specific transit situations.

February 2025 — Initial China IEEPA Tariff (+10%)

The administration separately imposed an initial 10% IEEPA tariff on Chinese-origin goods, citing national security concerns related to fentanyl precursor chemical exports. The exact effective date was in February 2025, shortly after the Canada/Mexico orders.

• Chinese goods (initial): +10% (HTS 9903.01.10)
• This was layered on top of existing Section 301 duties, not a replacement for them

March 2025 — China IEEPA Escalation (+20%)

The administration escalated the China IEEPA rate.

• Chinese goods: +20% (HTS 9903.01.11), replacing the February rate

April 2025 — “Reciprocal Tariffs” and China Escalation

Two significant actions occurred in April 2025:

1. China escalation to +34% (HTS 9903.01.12)
2. Reciprocal tariff executive order: Applied IEEPA rates to dozens of trading partners based on their tariff and non-tariff trade barriers. Rates varied by country, ranging from ~20% for EU goods to 49% for Cambodian goods. Effective mid-April 2025.

This is the broadest expansion of the IEEPA tariff program. Importers sourcing from Vietnam, Bangladesh, Cambodia, Japan, South Korea, Taiwan, India, the EU, and many other countries first encountered IEEPA tariffs in April 2025.

May 2025 — China Escalation to +84%

• Chinese goods: +84% (HTS 9903.01.13)

By this point, the combined Section 301 + IEEPA burden on many Chinese goods exceeded 100% of customs value.

June 2025 — China Escalation to +125%

• Chinese goods: +125% (HTS 9903.01.14)

This is the highest IEEPA rate in the program’s history. Importers who received Chinese goods in June 2025 or later — before the Supreme Court ruling — paid IEEPA tariffs at this peak rate. For goods with significant customs value, the IEEPA duty amounts at this rate represent very substantial refund claims.

February 20, 2026 — Supreme Court Ruling Ends IEEPA Tariffs

The Supreme Court’s decision in Learning Resources, Inc. v. Trump invalidated all IEEPA tariffs. As of this date, no new IEEPA tariff obligations arose. The tariffs collected from February 2025 through February 20, 2026, are the amounts now eligible for refund.

What “Effective Date” Means for Your Entry

The date that matters for IEEPA eligibility is your entry date — the date CBP assigned to your entry when goods cleared customs. This is distinct from:

• The date goods were shipped from the supplier
• The date goods arrived at the U.S. port
• The invoice date
• The date your broker submitted the entry

Your CBP Form 7501 will show the “entry date” in the header section. If that date falls after the relevant executive order’s effective date and before February 20, 2026, the IEEPA tariffs on that entry are eligible for refund (subject to Phase 1 liquidation requirements).

Phase 1 Date Cutoff: January 30, 2026

There is an important nuance in Phase 1’s scope: the CAPE portal’s Phase 1 covers entries with a liquidation date (not entry date) that is either unliquidated as of the filing date, or liquidated within the past 80 days.

What this means practically: entries from the early IEEPA period (February–April 2025) that were liquidated promptly may have been liquidated more than 80 days ago by the time you file, putting them outside Phase 1’s scope. These entries will need to be addressed in a future CAPE phase.

For most importers, the optimal Phase 1 targets are:

• All currently unliquidated IEEPA entries (regardless of entry date)
• Entries liquidated within the past 80 days from your filing date

Related Resources

• Complete IEEPA Tariff List — Full list with rates and codes by date
• IEEPA Tariffs by Country — Which countries were affected at each stage
• Phase 1 vs. Future Phases — Which entries fall into which phase
• Check Your Eligibility