The Apparel Industry’s IEEPA Exposure
The U.S. apparel and textile industry has historically sourced production from countries with lower labor costs — primarily in Asia. In 2025, many of those same countries faced the highest IEEPA reciprocal tariff rates: Vietnam at 46%, Bangladesh at 37%, Indonesia at 32%, and India at 18%. The result was an unprecedented duty burden on clothing, footwear, and textiles that squeezed margins across the industry.
For apparel brands, retailers, and importers who absorbed these costs — or who raised prices to pass them to consumers — the IEEPA refund opportunity via CAPE is one of the most significant financial events in recent industry history.
Key Product Categories and HTS Codes
Woven Apparel (Chapter 62)
- 6201.11–19: Men’s overcoats and jackets
- 6203.42: Men’s trousers and shorts, cotton
- 6204.62: Women’s trousers and shorts, cotton
- 6206.90: Women’s blouses and shirts
- 6211.42–43: Tracksuits, skiwear, swimwear
Knitted Apparel (Chapter 61)
- 6109.10: T-shirts, singlets, and other vests, cotton
- 6110.20: Jerseys, pullovers, and cardigans, cotton
- 6104.62: Women’s trousers and shorts, knitted cotton
- 6111.20: Babies’ garments, cotton
Textile Articles (Chapters 50–60)
- 5208.21: Woven cotton fabric, plain weave
- 5512.11: Woven synthetic fiber fabric
- 6307.90: Other made-up textile articles
Vietnam: The Largest Opportunity
Vietnam’s 46% IEEPA rate made it the highest-exposure country for apparel importers outside of China. A retailer importing $5 million in Vietnamese clothing and accessories during the IEEPA period could have CAPE refund eligibility of $2.3 million or more (including estimated interest).
Vietnam is a major source of casualwear, athletic wear, outerwear, and accessories for U.S. brands and retailers. Companies that built or expanded Vietnamese production capacity in recent years — often specifically to diversify away from China — faced a particularly harsh IEEPA burden.
Bangladesh: Knitwear and Ready-Made Garments
Bangladesh is one of the world’s largest exporters of ready-made garments. At a 37% IEEPA rate, the duty burden on Bangladeshi apparel imports was substantial. Bangladesh specializes in basic knitwear — t-shirts, polo shirts, fleece, and casual pants — categories that are imported at very high volumes.
China: The Section 301 Complexity
For apparel importers from China, IEEPA tariffs were assessed on top of existing Section 301 tariffs (which range from 7.5% to 25% for most apparel HTS codes). Only the IEEPA-specific duty layer is refundable. When preparing your CAPE filing, ensure you separate IEEPA duty amounts from Section 301 duty amounts on each entry.
Brand and Retailer Considerations
Large apparel brands and retailers who import under their own EIN — rather than purchasing finished goods from domestic distributors — are eligible claimants. Brands that use an owned or licensed sourcing subsidiary as the IOR should confirm the subsidiary’s EIN matches the CAPE filing.
Brands that purchased goods from U.S. domestic wholesalers (who were the IOR on the import) are not eligible — the refund would go to the domestic wholesaler who was the IOR, not the end buyer.