Textile importers and IEEPA
Textiles have the messiest stacking profile of any industry. A single entry can carry a base column-1 duty (0–20%), a Section 301 layer if China-origin, and IEEPA on top. USMCA / CAFTA-DR preferential treatment excludes some entries from IEEPA entirely — and when IEEPA was charged on a preferential-qualifying entry, the correction path is not CAPE but a preferential-reconciliation claim.
Common HTS chapters in scope
- Chapter 50 — silk
- Chapter 51 — wool, fine or coarse animal hair; horsehair yarn and woven fabric
- Chapter 52 — cotton
- Chapter 54 — man-made filaments
- Chapter 55 — man-made staple fibers
- Chapter 56 — wadding, felt and nonwovens; special yarns
- Chapter 58 — special woven fabrics; tufted textile fabrics
- Chapter 60 — knitted or crocheted fabrics
Why the cliff matters for textiles
Textile entries liquidate at a normal pace — roughly 6–9 months from entry. Mid-2025 entries are hitting liquidation in early-to-mid 2026, which puts their 80-day cliff in summer 2026. Filing wave 1 should cover the earliest-liquidated entries before the cliff tightens.
Typical refund structure
Textile refund bands track import volume linearly. A mill importing $5M of Chapter 52 cotton fabric with a 15% IEEPA layer recovers $750K of principal plus interest. Because textile entries stack multiple tariff regimes, the audit trail — per-line rule ID logs from un-tariff's classifier — matters if CBP asks for reconciliation.
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 textiles volume. If the number warrants it, see pricing for the flat-fee filing tiers.
Common questions
We're USMCA-qualifying — do we even have IEEPA exposure?
Many USMCA-qualifying textile entries were excluded from IEEPA. If IEEPA was charged, that's likely a preferential-treatment error, not a CAPE case. un-tariff flags these with IEEPA-006 so you can route them to counsel rather than include them in the CAPE file.
What about greige versus finished fabric classification?
HTS classifies greige and finished fabric under different subheadings (same chapter, different 4–6 digit codes). IEEPA treatment can differ between them — the registry handles this automatically. If your ACE export groups greige and finished under the same style, the classifier still separates them by HTS.
Does the refund apply to yarn?
Yarn imports (Chapters 50–55) that paid IEEPA are refundable on the same terms as fabric — 80-day cliff, CBP validation, interest walk. un-tariff treats yarn and fabric entries identically; the classification is HTS-driven.
What if we're a small mill with only a few dozen entries?
CAPE files are not volume-gated — you can file even one entry. un-tariff's flat fee structure makes software economical even for small books. If you have fewer than ~20 entries, DIY is also realistic; see un-tariff vs DIY CAPE filing.