Apparel importers and IEEPA
Apparel is the textbook IEEPA stacking case. A single entry line can carry a base column-1 duty (8–32%), a Section 232 steel-content surcharge if applicable, and an IEEPA tranche on top. Only the IEEPA layer refunds. For most apparel importers the Section 232 piece is small or zero, but the base duty stays collected — expect the refund to be cleanly the IEEPA tranche percentage of dutiable value.
Common HTS chapters in scope
- Chapter 61 — articles of apparel, knitted or crocheted
- Chapter 62 — articles of apparel, not knitted or crocheted
- Chapter 63 — other made-up textile articles
- Chapter 64 — footwear
- Chapter 99 IEEPA subheadings layered on top of the above
Why the cliff matters for apparel
Apparel entries liquidate fast because CBP targets them for early liquidation review, so the 80-day cliff arrives sooner than for capital-goods imports. A shipment that entered in January 2026 often liquidates within 90 days; add 80 days and the cliff falls in late summer 2026. Track liquidation dates weekly — the clock moves.
Typical refund structure
Apparel importers with $2M–$10M annual dutiable value typically recover mid-six to seven figures including interest. Refunds track volume linearly — this is a commodity pattern. un-tariff's per-line stacking separation matters here because apparel lines often stack base duty + IEEPA cleanly, and getting the math wrong by hand is easy.
HTS chapters in scope
| HTS Chapter | Typical product | IEEPA scope | Typical duty rate (IEEPA-affected entries) |
|---|---|---|---|
| Chapter 61 | Knit apparel — T-shirts, sweaters, hosiery | Fully covered | additional IEEPA rate |
| Chapter 62 | Woven apparel — suits, trousers, blouses, outerwear | Fully covered | additional IEEPA rate |
| Chapter 63 | Made-up textile articles — blankets, bed linen, bags | Fully covered | additional IEEPA rate |
| Chapter 64 | Footwear with leather uppers (non-Chapter 61/62 classified) | Partial — exclusions apply | varies |
| Chapter 42 | Leather goods — handbags, wallets, travel goods | Partial — exclusions apply | additional IEEPA rate |
Typical refund bands for this sector
These bands reflect typical IEEPA exposure observed across public trade-data aggregates for the sector. Actual refund depends on your specific HTS mix, origin country, and exclusion profile — run the free calculator for your numbers.
| Typical dutiable value | Typical IEEPA exposure % | Typical refund band (low–high) |
|---|---|---|
| $500K | 12–18% | $60K–$90K |
| $2M | 12–18% | $240K–$360K |
| $10M | 12–18% | $1.2M–$1.8M |
Cost comparison for this industry
A $300K apparel refund at a 15% broker contingency costs $45,000 in fees. un-tariff's Standard tier ($799) handles the same filing for under 0.3% of the refund.
How un-tariff helps
- Runs your ACE Entry Summary against the versioned IEEPA HTS registry — no manual lookups.
- Separates stacked Section 232 / Section 301 duty from IEEPA principal automatically, so the refund number is defensible.
- Flags every entry within 14 days of the 80-day cliff so the time-sensitive ones ship first.
- Computes CBP quarterly interest with the correct daily compounding across rate boundaries.
- Validates the CAPE CSV against all CBP VAL-F/E/I rules before you download — no surprise rejections.
Next steps
Start with the free calculator to see the refund band for your apparel volume. If the number warrants it, see pricing for the flat-fee filing tiers.
Common questions
Are my USMCA-qualifying apparel entries excluded from IEEPA?
In many tranches, yes. USMCA-qualifying apparel from Canada or Mexico was excluded from several IEEPA executive orders. un-tariff's IEEPA-006 rule flags exclusion candidates; if the classifier sees USMCA-qualifying goods that paid IEEPA anyway, that's a correction that may involve a USMCA-reconciliation claim rather than a straight CAPE filing.
What about Haiti / CAFTA-DR preferential entries?
Similar pattern — preferential-treatment apparel entries generally fall outside IEEPA scope. If IEEPA was charged, the recovery path may be preferential-treatment correction rather than CAPE. Talk to a customs attorney for the edge cases.
Do I need a customs broker for apparel refunds?
For standard in-window CAPE filings, no. Apparel entries are usually high-volume but clean — a validated CSV works. For protest-track entries or preferential-treatment corrections, engage counsel.
How does per-style classification work?
un-tariff classifies at the HTS-subheading level, not at the garment-style level. Every apparel style maps to one HTS subheading per destination classification; the refund applies to the subheading's paid-duty tranche.