Countries·5 min read

Thailand IEEPA Tariffs: What Importers Need to Know

How IEEPA reciprocal tariffs affected imports from Thailand, who qualifies for a refund, and what to do next. Covers rate changes, carveouts, and Chapter 99 codes.

By Paige W.··Updated March 3, 2026

Quick Answer

MetricValue
IEEPA tariff rate+10% baseline, one-day +36% spike, then +19%
Collection windowApr 5, 2025 -- Feb 24, 2026
Major carveoutsAnnex II products, Section 232 goods, in-transit
Aug 7 changeNew heading 9903.02.61 becomes the default for Thailand-origin goods
Current statusSection 122 (+10%) replaced IEEPA

Overview

Thailand is a major U.S. import corridor with a broad product mix (electronics, machinery, auto parts, rubber products, food products, and consumer goods). During the IEEPA reciprocal tariff program, Thailand-origin goods experienced both a one-day rate spike and a later re-platforming change that set a new default rate for the rest of the program window.

The reciprocal tariff program began on April 5, 2025 with a +10% baseline add-on for most countries. On April 9, 2025, Thailand moved to a country-specific reciprocal rate of +36% for one day only. On April 10, the country-specific rates were suspended, and Thailand reverted back to the +10% baseline.

On August 7, 2025, CBP re-platformed the reciprocal tariff program to new Chapter 99 headings for countries listed in the July 31, 2025 order. Thailand’s post-August default reciprocal rate became +19% under a new heading, while major exceptions (Annex II exclusions, Section 232 goods, U.S. content, and in-transit windows) continued to apply.

The IEEPA reciprocal tariff ended on February 24, 2026, following the Supreme Court’s ruling in Learning Resources v. Trump. On the same day, a temporary Section 122 import surcharge of +10% took effect for most countries, including Thailand.

Informational only -- not legal advice.

What Changed: Rate Timeline

DateWhat happenedAdditional duty
Apr 5, 2025Reciprocal tariffs begin (baseline)+10%
Apr 9, 2025Thailand country-specific reciprocal rate takes effect+36% (one day only)
Apr 10, 2025Country-specific rates suspended back to baseline+10%
Aug 7, 2025Re-platformed under new headings; Thailand rate set+19%
Feb 24, 2026IEEPA revoked following Supreme Court ruling0% (IEEPA layer ends)
Feb 24, 2026Section 122 surcharge begins+10%

Exceptions and Carveouts

Not every Thailand-origin import was subject to the default reciprocal rate. The following exceptions applied during the IEEPA collection window.

ExceptionWho qualifiesEffect
Annex II exclusion listProducts on the enumerated HTS exclusion listExempt from reciprocal tariff
Section 232 goodsSteel, aluminum, vehicles, semiconductors, copper, and related productsExempt from reciprocal tariff
In-transit goodsTime-limited windows for goods loaded before program changesExempt or reduced rate (depends on window)
>=20% U.S. contentProducts with at least 20% U.S.-origin contentPartial relief (content-based reduction)
Civil aircraftCivil aircraft and related partsExempt under Section 122

If your goods qualified under one of these exceptions, the IEEPA surcharge either did not apply or applied at a reduced level.

What This Means for Your Refund

If you imported non-exempt goods from Thailand between April 5, 2025 and February 24, 2026, you may have paid an additional 10%, 36%, or 19% in IEEPA reciprocal duties on top of your normal tariff rate. Following the Supreme Court’s ruling in Learning Resources v. Trump, those 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

If you are unsure whether your entries qualify, the fastest way to find out is to check your customs documents for Chapter 99 codes like 9903.01.25, 9903.01.65, or 9903.02.61.

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Most importers don't have their customs records on hand. We'll guide you through requesting them from your carrier or broker.

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Chapter 99 Code Reference

This section is for customs brokers, trade compliance teams, and anyone reviewing entry summaries at the line-item level. Each Chapter 99 code corresponds to a specific IEEPA or Section 122 treatment.

CodeDescriptionRateWindow
9903.01.25Reciprocal baseline+10%Apr 5, 2025 -- Feb 24, 2026
9903.01.65Thailand reciprocal (one-day)+36%Apr 9, 2025 only
9903.02.61Thailand reciprocal (re-platformed)+19%Aug 7, 2025 -- Feb 24, 2026
9903.01.28In-transit carveout0%Apr 5 -- Jun 16, 2025
9903.01.32Annex II exclusion list0%Apr 5, 2025 -- Feb 24, 2026
9903.02.01Transshipment penalty+40%Aug 7, 2025 -- Feb 24, 2026
9903.03.01Section 122 default+10%Feb 24, 2026 -- Jul 24, 2026

Need help getting your documents?

Most importers don't have their customs records on hand. We'll guide you through requesting them from your carrier or broker.

Get Started

Informational only — not legal advice. RefundArrow is not a law firm, and this resource does not create an attorney‑client relationship with Himmelstein & Adkins, LLC. Tariff/refund outcomes depend on your facts, entry records, and evolving CBP/court guidance; consult qualified customs counsel for advice on your situation.

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