China IEEPA Tariff Refunds: 34% Rate Explained
China was one of the three countries targeted in the first wave of IEEPA tariff actions, with a 34% reciprocal rate taking effect on February 4, 2025. By total dollar value, China generates the largest IEEPA refund pool of any single country — simply because China is the United States’ largest import source, with hundreds of billions of dollars in annual imports.
The Section 301 Complication
This is the most important caveat for Chinese goods: Section 301 tariffs are not refundable. Section 301 tariffs were imposed under the Trade Act of 1974 — a completely separate legal authority from IEEPA — and were not challenged in the V.O.S. Selections litigation. They remain fully in effect.
Many Chinese imports bear both Section 301 and IEEPA duties on the same CBP Form 7501. The CAPE refund process applies only to the IEEPA duty layer. You must identify and claim only IEEPA-specific duty amounts.
Section 301 duty rates for Chinese goods vary by product “list”:
- List 1: 25% on approximately $34B in goods
- List 2: 25% on approximately $16B in goods
- List 3: 25% on approximately $200B in goods
- List 4A: 7.5% on approximately $120B in goods (consumer goods)
Your CBP 7501 will show these as separate duty assessments with different collection codes. Work with your customs broker to isolate the IEEPA-specific amounts for CAPE filing.
Key Import Categories from China
Electronics and Machinery (Chapters 84–85): Computers, smartphones, circuit boards, industrial machinery, home appliances. High-value category with substantial IEEPA exposure.
Textiles and Apparel (Chapters 50–63): Despite having moved much production to Vietnam and Bangladesh, China remains a significant apparel and textile source. Check for both IEEPA and Section 301 duty layers.
Furniture (Chapter 94): Office furniture, bedroom sets, seating, outdoor furniture. Existing antidumping orders on wooden bedroom furniture add complexity.
Toys and Games (Chapter 95): China dominates toy manufacturing. IEEPA layer on top of Section 301 is the specific refund target.
Plastics and Rubber (Chapters 39–40): Industrial and consumer plastic goods.
Effective Date and Coverage
For goods from China, the IEEPA coverage period begins February 4, 2025. Any consumption entry with a filing date on or after February 4, 2025 that had IEEPA duties assessed is potentially eligible for a CAPE refund.
Note that the IEEPA rate for China may have escalated above the baseline 34% during the coverage period as the administration and China engaged in retaliatory tariff exchanges. The specific rate applicable to each entry depends on the executive order(s) in effect on the entry date. CBP’s records contain the actual rate applied to each entry — use those rates in your CAPE CSV rather than a uniform 34%.
How to Estimate Your Refund
Use our free calculator above to estimate your China IEEPA refund. Enter your total import value from China, select China from the country dropdown, and we’ll estimate your duty refund and potential interest component. Remember that the actual refund will be based on the per-entry IEEPA duty amounts from your 7501s, not a blended calculation.
Notes on the IEEPA Rate Escalation
During the covered period, the administration and China engaged in a tariff escalation cycle. The 34% baseline IEEPA rate climbed through several executive orders before settling. For CAPE purposes, each entry is assessed at whatever rate was in effect on its specific entry date. Your CBP 7501 shows the rate applied to each entry.