China IEEPA Tariffs: What Importers Need to Know

Overview

China is the third-largest U.S. trading partner, with roughly $580--600 billion in bilateral trade in 2024. The most heavily traded categories include electronics and components, machinery, furniture, toys, and apparel and textiles. Because of this volume, the IEEPA tariffs affected an enormous range of importers across virtually every consumer and industrial sector.

China is unique among all IEEPA-affected countries because two separate IEEPA programs applied simultaneously. The first was the fentanyl/opioid program, which imposed an additional 10% duty on all China-origin goods starting February 4, 2025, increasing to 20% on March 4, 2025. The second was the reciprocal tariff program, which began on April 5, 2025, and was layered on top of the fentanyl duty. From April 10 through May 13, 2025, the reciprocal rate for China spiked to 125% -- meaning non-exempt importers faced up to 145% in IEEPA duties alone, on top of existing base duties.

After May 14, 2025, the reciprocal rate for China returned to 10%, bringing the typical combined IEEPA surcharge to 30% (20% fentanyl + 10% reciprocal) for most non-exempt goods. That rate held until IEEPA ended on February 24, 2026, following the Supreme Court's ruling in Learning Resources v. Trump. On the same day, a new Section 122 surcharge of 10% took effect.

It is important to understand that Section 301 duties -- the "trade war" tariffs imposed on China goods in 2018--2019 -- are entirely separate from IEEPA. Those duties remain in effect and are not affected by the Supreme Court ruling. Only the IEEPA layers (fentanyl and reciprocal) may be refundable.

Informational only — not legal advice.

What Changed: Rate Timeline

Exceptions and Carveouts

Because China had two stacking IEEPA layers, exceptions could apply to one or both. A carveout that eliminated the reciprocal layer still left the fentanyl layer in place, and vice versa.

What This Means for Your Refund

If you imported non-exempt goods from China between February 4, 2025 and February 24, 2026, you may have paid additional IEEPA duties -- potentially at combined rates of 30% to 145% -- on top of your normal tariff rate. Following the Supreme Court's ruling in Learning Resources v. Trump, those IEEPA duties may be refundable.

The type of filing depends on your entry's liquidation status:

• Unliquidated entries may be corrected through a Prior Disclosure or Post-Summary Correction (PSC)
• Liquidated entries typically require a Form 19 protest, which must be filed within 180 days of liquidation

IEEPA duties are separate from Section 301 duties and Section 232 duties. Those programs are not affected by the Supreme Court ruling and are not refundable through this process. If you are reviewing your customs documents, focus on the China IEEPA-specific 9903.01.* codes listed below and review the full Chapter 99 line because other 9903.* headings can be carveouts or separate programs.

Chapter 99 Code Reference

Each Chapter 99 code corresponds to a specific IEEPA duty layer or carveout. China entries may have codes from both the fentanyl and reciprocal programs.