E-Commerce Importers and IEEPA
The e-commerce sector was among the hardest hit by IEEPA tariffs. Online retailers and marketplace sellers who import products directly from overseas manufacturers — bypassing domestic distributors — bore the full IEEPA duty burden as importers of record.
For e-commerce businesses that imported products from China, Vietnam, Bangladesh, or other covered countries during 2025, the CAPE refund represents a meaningful cash recovery. A business importing $2 million per year in Chinese goods at a 34% IEEPA rate could have paid $680,000 in IEEPA duties over the covered period.
Eligibility Fundamentals
You are eligible if: (1) your business or its owner is listed as the importer of record on CBP Form 7501 entries during the IEEPA coverage period, (2) IEEPA duties were actually assessed and collected on those entries (not $0), and (3) you are filing through the CAPE portal as the IOR or through a licensed customs broker with your power of attorney.
Direct-to-Consumer Import Models
Many e-commerce businesses use several import models, each with different implications:
DTC brand with warehouse: You import containers or air freight shipments to your own U.S. warehouse. You are the IOR. You are eligible.
3PL fulfillment: You import to a third-party logistics provider’s warehouse. The IOR is typically still you — the 3PL files entries on your behalf. Confirm by checking your 7501s.
Dropshipping (overseas to consumer): If your overseas supplier shipped directly to U.S. customers, the supplier may have been the IOR under DDP terms. You may not be eligible in this model.
Marketplace pass-through (Amazon FBA, Walmart Fulfillment): Same as “self-importing seller” above — you are the IOR if you arranged the import and filed entries under your EIN.
Platform Sellers vs. Own-Site Sellers
The distinction between selling on a marketplace (Amazon, eBay, Etsy, Walmart Marketplace) and selling on your own e-commerce site (Shopify, WooCommerce, etc.) doesn’t affect CAPE eligibility. What matters is whether you were the IOR on the import entries — the sales platform is irrelevant.
Getting Your Entry Data
Most e-commerce businesses use a freight forwarder or customs broker to handle imports. Contact them and request:
- All entry summaries (CBP 7501) for imports from covered countries during the IEEPA period
- Specifically: entry number, HTS code, country of origin, dutiable value, and IEEPA duty paid per line
Compile this data into a spreadsheet. This becomes the basis for your CAPE CSV submission.
Use our free calculator to estimate your total refund while you gather the detailed data needed for actual filing.