IEEPA Tariffs Explained: What Was Collected, and What Replaced Them

In April 2025 the United States imposed tariffs on virtually every country in the world through an executive order citing the International Emergency Economic Powers Act (IEEPA). Those tariffs changed landed cost for importers beyond the China-only Section 301 program.

They are not part of the current duty stack. On February 20, 2026, the Supreme Court invalidated the use of IEEPA to impose these tariffs. CBP stopped collecting them. Entries that paid IEEPA duty are a refund problem, covered in the CAPE refund guide. The replacement layers are separate statutes: a 10% Section 122 surcharge from February 24 through July 24, 2026, and then the Section 301 forced-labor tariffs that took effect the morning Section 122 expired.

The rest of this post explains what IEEPA was, because refund claims and old landed-cost models still depend on that structure. Do not use the rates below as the bill on a new entry.

What Is IEEPA?

The International Emergency Economic Powers Act (50 USC §§ 1701–1708) grants the President broad authority to regulate international commerce when a national emergency has been declared. Historically, it was used to freeze assets of hostile governments, impose sanctions on terrorist organizations, and cut off financial flows to adversaries.

Using IEEPA to impose broad tariffs on friendly trading partners was legally novel in 2025. The statutory text allows the President to "regulate" international commerce during a national emergency, and the administration interpreted this as including tariff imposition. The authority was challenged immediately. On February 20, 2026, the Supreme Court held that this use of IEEPA was invalid. Collection stopped. The practical question for old entries is the refund path, not whether to accrue IEEPA on the next shipment.

The Tariff Structure

The IEEPA tariff regime that took effect in 2025 established a 10% baseline tariff on imports from most countries, with significantly higher rates for countries with which the US has large trade deficits.

Rates vary by country and have been subject to modification. The baseline 10% applies to imports from the European Union, the United Kingdom, Japan, South Korea, Australia, New Zealand, and dozens of others. Higher country-specific rates were announced for certain major trading partners.

Important: IEEPA tariff rates have been subject to executive modification, pauses, and negotiations since their initial announcement. Always verify current rates with CBP or a licensed customs broker before making import decisions. Rates published here reflect our best understanding at the time of writing and may not reflect the current position.

How IEEPA Stacks With Other Tariffs

The critical thing about the 2025–early 2026 program is that IEEPA tariffs stacked on top of existing duties. They did not replace them. The figures below are historical. They are not the rate on an entry filed today.

Example — German-origin machinery (HTS 8457.10.0000):

A piece of German machinery that had carried only a 4.4% duty carried 14.4% while the IEEPA layer was in force. That more than tripled the duty cost on those entries.

For Chinese-origin goods the stacking with Section 301 tariffs is even worse:

Example — Chinese-origin furniture (HTS 9403.60.8081):

Chinese-origin goods were already subject to Section 301. IEEPA added another layer on top, and in some cases this made Chinese-origin goods effectively uneconomical for many importers.

USMCA and IEEPA

Mexico and Canada are covered by the United States-Mexico-Canada Agreement (USMCA), which established a free trade zone with preferential duty rates. IEEPA tariffs raised obvious questions about how the two regimes interact.

The current position is that USMCA-qualifying goods (those meeting the applicable rules of origin) may be exempt from IEEPA tariffs or subject to reduced rates. Non-USMCA goods transiting through Mexico or Canada without genuine origin do not get this treatment.

This distinction has made origin verification and USMCA qualification documentation more important than ever. Importers sourcing from Mexico should ensure they have proper certificates of origin and that their goods genuinely meet USMCA rules, not just routing goods through Mexico to avoid tariffs.

Which Products Are Affected

The breadth of IEEPA tariffs is one of their defining characteristics. Unlike Section 301, which targeted Chinese goods specifically, IEEPA tariffs apply globally. Affected categories include:

• European goods: German industrial machinery, Italian fashion, French wine, pharmaceutical ingredients from Ireland
• Southeast Asian goods: Vietnamese textiles and footwear, Thai electronics, Malaysian semiconductors
• Indian goods: pharmaceutical APIs, jewelry, textiles
• Japanese goods: automotive components, precision instruments, electronics
• Consumer goods across all origins: clothing, electronics, appliances, food products

Industries that had diversified away from China specifically to avoid Section 301 tariffs are now finding that their alternative sourcing countries also carry IEEPA tariffs, though generally at lower rates than the Section 301 regime.

Compliance Considerations

Classification accuracy is now more important than ever

With duty rates elevated across virtually all origins, the financial consequence of misclassifying a product has grown proportionally. A product incorrectly classified at a 2% rate instead of a correct 5% rate, plus Section 301, plus IEEPA, can mean the difference between a small duty bill and a very large one. CBP audits and penalty exposure (usually surfacing as a CF-28 request for information or CF-29 notice of action) scale with the underpayment.

Record country of origin carefully

Because IEEPA rates vary by country, accurate country of origin documentation is essential. Goods with ambiguous origin (assembled in multiple countries, using components from various sources) need proper substantial transformation analysis.

Watch for modifications

IEEPA tariffs were set by executive order and, while they lasted, could be modified, suspended, or eliminated without a rulemaking. Many importers saw the rate change on goods already in transit. That is also why contracts from that period need a tariff-adjustment clause if the same goods now sit under a different statute.

Strategies That Applied While IEEPA Was Being Collected

These were the operational responses from April 2025 until collection stopped on February 20, 2026. For a shipment now, model Section 301 forced-labor duties and any Section 232 or AD/CVD layer, not IEEPA.

Re-evaluate total landed cost. With IEEPA tariffs added to the calculation, many sourcing decisions made in 2023 or 2024 may no longer be optimal. Run the full landed cost calculation (including base duty, Section 301 where applicable, IEEPA, MPF, and HMF) for your current sources.

Investigate USMCA qualification more aggressively. For goods sourced from Canada and Mexico, confirming USMCA qualification could eliminate or reduce IEEPA exposure. Rules of origin analysis requires detailed knowlege of your supply chain.

Consider duty drawback. If you're exporting finished goods that incorporate imported materials subject to IEEPA tariffs, drawback applies. As with Section 301, IEEPA duties paid on imported goods used in exported products can be recovered at 99%.

Stay in dialogue with your customs broker. The IEEPA tariff environment is the most fluid it has been in decades. Rate changes, country exemptions, and negotiated carve-outs are announced with little notice. A broker who tracks these changes can alert you before they hit your cost structure.

What to Tell Your Suppliers and Customers

If you're passing IEEPA tariff costs to customers, be explicit in your contracts and invoices. Tariff costs that were built into a fixed-price contract may now be your problem if the contract doesn't include a tariff adjustment clause.

For future contracts, consider:

• Tariff adjustment clauses: allow prices to be renegotiated if tariff rates change by more than a defined threshold
• Country-of-origin representations: require suppliers to warrant the origin of goods, so that if tariff liability arises due to incorrect origin, you have a contractual remedy
• Force majeure review: tariff changes may or may not qualify as force majeure under your contracts. Review with counsel.

Key Takeaways

• IEEPA tariffs imposed a baseline 10% on most US imports from April 2025 until the Supreme Court invalidated them on February 20, 2026. CBP is not collecting that layer on new entries.
• While they were in force they stacked on base HTS duties and Section 301. Refunds for duty already paid run through CBP's CAPE process, not through a new IEEPA line on the entry.
• The current broad additional-duty layer is the Section 301 forced-labor action that replaced the expired Section 122 surcharge on July 24, 2026.
• USMCA qualification mattered for the old IEEPA layer. It does not, by itself, remove Section 338 on covered Canadian goods or the forced-labor Section 301 rates.
• Duty drawback can still apply to IEEPA duties that were paid on goods later exported. That is a refund of a closed program, not a reason to model IEEPA on a new shipment.

Related guides

• Section 301 complete guide — The China-specific duties that IEEPA stacks on top of.
• Country of origin & USMCA — How origin determines which country's IEEPA rate applies.
• AD/CVD practical guide — The third duty layer that compounds IEEPA on covered products.

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Use the TariffClassify landed cost calculator for the duty stack on a new entry. IEEPA is not one of the current layers. The IEEPA refund guide is the page to use for duty that was already paid.