The International Emergency Economic Powers Act (IEEPA) tariffs that the Supreme Court struck down on February 20, 2026 were not a single, uniform duty. Instead, they were a collection of executive orders, proclamations, and amendments that imposed different tariff rates on different countries and, in many cases, different products from the same country.
Understanding which tariff rates applied to which countries and products is essential for importers calculating their refund exposure. This article provides a comprehensive reference.
China: The Highest Rates
China faced the most aggressive IEEPA tariffs. The rates varied by product category and evolved over time, but the headline rates were:
- List 1 (July 2018): 25% on approximately 1,300 HTS codes
- List 2 (August 2018): 25% on approximately 6,000 HTS codes
- List 3 (September 2018): 10% on approximately 5,000 HTS codes
- List 4A (September 2019): 15% on approximately 3,500 HTS codes
- List 4B (December 2019): 7.5% on approximately 1,200 HTS codes
- Section 301 Increases (2020–2021): Additional increases bringing rates on some products to 25%, 30%, or higher
The effective rate for any given Chinese import depended on the specific HTS code of the product. Some Chinese goods faced cumulative rates exceeding 145% when multiple tariff actions were layered on top of each other.
Canada and Mexico: 25% Across the Board
Canada and Mexico faced a more uniform tariff regime under IEEPA:
- Canada: 25% on most goods imported from Canada, imposed under Section 232 (national security) authority, which was considered part of IEEPA by the Supreme Court
- Mexico: 25% on most goods imported from Mexico, also under Section 232
Unlike the China tariffs, which were highly product-specific, the Canada and Mexico tariffs applied broadly across most HTS codes, with limited exceptions for certain agricultural products and other designated items.
Other Countries: Selective Tariffs
Beyond China, Canada, and Mexico, IEEPA-based tariffs were imposed on selective products from other countries:
- Vietnam: Approximately 46% on certain steel and aluminum products
- India: Approximately 26% on certain steel and aluminum products
- Bangladesh: Approximately 37% on certain steel and aluminum products
- European Union: 20% on certain steel and aluminum products
- South Korea: 25% on certain steel and aluminum products
These tariffs were primarily focused on steel and aluminum products and were imposed under Section 232 (national security) authority.
How to Determine Your Tariff Rate
To calculate your refund exposure, you need to know the specific tariff rate that applied to each of your entries. Here is how to find it:
Step 1: Gather Your Entry Data — Collect your CBP Form 7501 (Entry Summary) for each import entry during the IEEPA period (roughly February 2018 through February 2026). The form will show the HTS code, the country of origin, and the duties paid.
Step 2: Cross-Reference the HTS Code — Use the HTS code to determine which tariff list(s) applied. The U.S. International Trade Commission (USITC) maintains detailed lists of HTS codes affected by each tariff action. These are publicly available on the USITC website.
Step 3: Calculate the Refund — Once you know the tariff rate, you can calculate the refund as: (Dutiable Value × Tariff Rate) + (Interest at 6% annually from the date of payment to the date of refund).
This is where working with an experienced customs broker or IEEPA refund specialist becomes valuable. The calculations can be complex, especially for entries subject to multiple tariff actions or entries with partial IEEPA exposure (where only some of the duties were IEEPA-based).
The Bottom Line
Your refund amount depends on the specific tariff rates that applied to your entries. Chinese imports likely faced the highest rates, while Canadian and Mexican imports faced a more uniform 25%. Other countries faced selective tariffs on specific product categories.
If you are preparing your IEEPA refund claim, start by organizing your entry data by country of origin and HTS code. This will make it easier to cross-reference the applicable tariff rates and calculate your exposure accurately.
Conglobus International can help you organize this data and calculate your refund exposure. Contact us for a free assessment.