Tariff Refunds for Apparel & Textile Importers Importers

Apparel and textile importers who paid IEEPA tariffs on Chinese, Canadian, or Mexican goods may qualify for refunds.

Apparel and Textile Importers: IEEPA Tariff Refund Eligibility

Apparel and textile importers occupy a complicated position in the IEEPA refund landscape. The industry’s global supply chains span China, Vietnam, Bangladesh, Cambodia, Mexico, and dozens of other countries — and only goods from certain origins carried IEEPA tariff surcharges. Identifying which entries are eligible requires careful review of both the sourcing country and the specific HTS codes applied.

Which Apparel and Textile Imports Were Affected

Chinese-origin goods: China remains the world’s largest apparel exporter, and IEEPA tariffs applied to Chinese-origin apparel at escalating rates throughout 2025. U.S. fashion brands, mass-market retailers, and specialty clothing companies that sourced from China paid substantial IEEPA surcharges on top of the existing textile tariff rates (which are already among the highest in the U.S. tariff schedule).

Canadian and Mexican goods (early 2025): The IEEPA tariffs imposed on Canada and Mexico in February 2025 briefly affected apparel manufactured in those countries, particularly goods that entered duty-free under USMCA. Many apparel entries that had previously paid zero duty under USMCA instead faced 25% IEEPA surcharges during the period those tariffs were in effect.

“Reciprocal” tariff countries: The administration’s “reciprocal” IEEPA tariffs extended to apparel-heavy sourcing countries including Vietnam, Bangladesh, Cambodia, and others. Importers who sourced from these countries during the relevant period should review their entries for IEEPA codes.

HTS Classification Complexity in Apparel

Apparel has one of the most complex tariff schedule structures of any product category. HTS Chapters 61 (knit) and 62 (woven) contain hundreds of specific classifications based on fiber content, construction method, garment type, and end use. Each classification has its own base tariff rate, and IEEPA codes were layered on top based on country of origin — not HTS classification.

This means that apparel importers may have entries where:

Some lines carried IEEPA surcharges (Chinese-origin garments)
Other lines on the same entry did not (Vietnam-origin garments under IEEPA reciprocal rules that may have been modified mid-year)
Some entries include both eligible and ineligible lines

The CAPE filing must accurately identify only the IEEPA-eligible lines. Overstating the eligible duties will result in a rejection during CBP’s recalculation step.

Eligibility Checklist for Apparel Importers

Did your entries include Chinese-origin apparel between February 2025 and February 2026?
Did your entries include Canadian or Mexican apparel during the IEEPA tariff periods (which varied through the year)?
Are IEEPA codes (9903.01.xx) listed on your CBP Form 7501 for those entries?
Are you listed as the Importer of Record on those entries?
Are the entries unliquidated or liquidated within the past 80 days?

IEEPA Tariffs by Country — Which source countries carried IEEPA surcharges
IEEPA Tariff List — Complete chronological list of tariff imposition dates
What Is the IEEPA Tariff? — Background on the law and the Supreme Court ruling
Check Your Eligibility — Full eligibility checklist