Vietnam IEEPA Tariffs: What Importers Need to Know

Overview

Vietnam is a top-ten U.S. trading partner, with roughly $140--150 billion in bilateral goods trade in 2024. The most heavily traded categories include electronics and smartphones, textiles and apparel, footwear, furniture, and machinery. Because of the volume and diversity of goods flowing from Vietnam, the IEEPA reciprocal tariffs affected a broad range of importers.

Starting April 5, 2025, the federal government imposed a 10% baseline reciprocal tariff on all Vietnam-origin imports under the International Emergency Economic Powers Act. On April 9, 2025, the country-specific reciprocal rate took effect at 46% -- the highest reciprocal rate announced for any country -- but it lasted only a single day before a 90-day suspension brought the rate back to 10%. On August 7, 2025, the program was re-platformed under new Chapter 99 headings and Vietnam's rate settled at 20%, where it remained for the rest of the IEEPA window.

Vietnam was also subject to a 40% transshipment penalty heading. CBP created this code to address goods routed through third countries to evade reciprocal duties -- a significant enforcement concern given Vietnam's role in regional supply chains. Exceptions included the Annex II exclusion list, Section 232 goods (steel, aluminum, copper, and derivatives), goods with at least 20% U.S. content, and qualifying in-transit shipments.

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 new Section 122 surcharge of 10% took effect for most countries, including Vietnam. For importers who paid the 10%, 46%, or 20% IEEPA duty on non-exempt goods, the key question now is whether those payments may be recoverable.

Informational only — not legal advice.

What Changed: Rate Timeline

Exceptions and Carveouts

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

If your goods qualified under one of these exceptions, the IEEPA surcharge either did not apply or applied at a reduced level. The Annex II exclusion list was updated on September 8, 2025.

What This Means for Your Refund

If you imported non-exempt goods from Vietnam between April 5, 2025 and February 24, 2026, you may have paid an additional 10%, 46%, or 20% in IEEPA 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

IEEPA duties are separate from Section 232 duties and Section 301 duties. Those programs are not affected by the Supreme Court ruling.

If you are unsure whether your entries qualify, check the full Chapter 99 line, not just the ordinary HTS. IEEPA-era entries commonly use 9903.01.* and, for many reciprocal programs, 9903.02.*.

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.