Tariff Refunds for Amazon Sellers / FBA Importers

Amazon FBA sellers may qualify for IEEPA tariff refunds. Learn the IOR challenge, eligibility criteria, and how to file.

Amazon FBA Sellers and IEEPA Tariff Refunds

Amazon FBA (Fulfillment by Amazon) sellers occupy a unique position in the IEEPA refund landscape. Many Amazon sellers import goods directly from Chinese manufacturers — making them potentially eligible for significant tariff refunds. But the specifics depend heavily on how inventory was imported and who was listed as the importer of record.

Amazon’s FBA program is a fulfillment service, not an import service. In most cases, the seller — not Amazon — is the importer of record for goods shipped directly to an Amazon fulfillment center. If you hired a freight forwarder, used a customs broker, and cleared your own goods through U.S. Customs, your IOR number should be on those entries. That means you hold the claim.

The IOR Question for Amazon Sellers

The critical question for every Amazon seller is: Who was the Importer of Record on your entries?

Scenario A: You were the IOR. You hired a customs broker, provided your EIN or CBP number, and your company is listed in Box 26 of Form 7501. In this case, you hold the refund rights directly and can file through the CAPE portal or authorize a recovery partner to file on your behalf.

Scenario B: Your freight forwarder or broker was the IOR. Some sellers, particularly those using agent services that bundle freight and customs clearance, may find that the freight forwarder is listed as IOR. In this case, the broker holds the formal claim right. You’ll need to work with them — either to have them file on your behalf or to assign claim rights to you via a legal agreement.

Scenario C: Amazon was involved in the import. Amazon has certain programs (particularly for international seller accounts and vendor arrangements) where Amazon entities may appear on customs documentation. If you’re unsure, pull your ACE entry records or ask your freight forwarder for copies of your CBP Form 7501 entries.

Why Amazon Sellers Were Particularly Exposed

Amazon sellers sourcing from China faced a double impact: IEEPA tariffs layered on top of many existing Section 301 duties, and those costs could not be easily passed through to Amazon’s price-sensitive marketplace. Amazon’s algorithm-driven Buy Box dynamics mean that sellers who raised prices to offset tariffs often lost sales to competitors who didn’t yet reflect the new costs — or to Amazon itself when it was a competing seller.

Categories with the heaviest IEEPA exposure for Amazon FBA sellers include:

Electronics accessories and gadgets (one of Amazon’s largest product segments)
Home and kitchen (storage, organization, small appliances)
Toys and games (especially battery-operated and electronic toys)
Sports and outdoors (fitness equipment, accessories)
Baby products (many manufactured in China)

What Amazon Sellers Should Do Now

Pull your ACE entry records. Log into your ACE account (or contact your customs broker) to retrieve CBP Form 7501 copies for all entries from February 2025 through February 2026. Look for HTS codes in the 9903.01.xx range — those are the IEEPA surcharge lines.
Confirm your IOR status. Check Box 26 of Form 7501. If your EIN or CBP importer number appears, you’re the IOR.
Estimate your IEEPA duty exposure. Your customs broker or ACE entry history will show the IEEPA duty amounts paid per entry. Sum these across the affected period.
Decide: DIY or partner. For FBA sellers with straightforward import histories and a single customs broker, self-filing CAPE may be feasible. For sellers with complex sourcing from multiple factories through multiple forwarders, a recovery partner typically produces faster and more complete results.

What Is an Importer of Record? — Understand who holds the refund rights
ACE Portal Setup: Step-by-Step — Get your ACE access configured for CAPE
DIY vs. Working with a Recovery Partner — Evaluate your options
E-Commerce Tariff Refunds — Broader e-commerce context