How Apparel and Footwear Brands Can File IEEPA Tariff Refunds Through CBP CAPE
Chen Cui Co-Founder of GingerControl What changed: The 2025 IEEPA rates are the ones collected (10% from April 5, 2025, then 20% for Vietnam and Bangladesh and 19% for Cambodia from August 7), not the April announcement, and the refund examples are recomputed. The Tariff Calculator no longer claims a per-entry refund export by CAPE line (the free ES-003 refund calculator totals IEEPA duty per entry), the Phase 2 answer reflects what Phase 2 and Phase 3 actually cover, and the $166 billion source is the CIT's October 8, 2026 opinion.
A DTC apparel brand claims an IEEPA refund by having its Importer of Record file a CAPE Declaration in ACE for every 2025 entry that paid an IEEPA Chapter 99 reciprocal duty (10% from April 5, 2025, then 20% for Vietnam and Bangladesh and 19% for Cambodia from August 7; China-origin goods also paid the fentanyl duty) and is still inside Phase 1's 80-day liquidation window. CBP refunds within 60 to 90 days.
Next step:Check every deadline on one entry
In this post
- Are footwear and apparel brands actually eligible for the IEEPA refund?
- TL;DR
- Why the IEEPA refund matters more to apparel than almost any other category
- The CAPE process, translated for DTC brands
- Step by step: what a DTC apparel brand does this week
- Vietnam vs Bangladesh vs Cambodia vs China: where is the refund largest?
- What about brands that ship under DDP or use a 3PL as IOR?
- How does the GingerControl approach compare to spreadsheet refund tracking?
- What apparel brands should NOT expect from CAPE
- FAQ
- Reclaim what was overcharged, then keep the corrected math accurate
- References
- Related industries
Are footwear and apparel brands actually eligible for the IEEPA refund?
Yes. Apparel (HTS Chapters 61, 62) and footwear (HTS Chapter 64) imports from every IEEPA reciprocal-tariff country are eligible for refund through CAPE, provided the entry contains a Chapter 99 IEEPA HTSUS code and is unliquidated or within 80 days of liquidation.
TL;DR
The Supreme Court's February 20, 2026 ruling in Learning Resources, Inc. v. Trump invalidated the IEEPA reciprocal tariffs that hit apparel and footwear brands hardest in 2025: 10% from April 5, then 20% on Vietnam and Bangladesh and 19% on Cambodia from August 7 (Executive Order 14326); the 46%, 49% and 37% rates announced in April applied only on April 9, 2025, before they were paused. On April 20, 2026, CBP launched the Consolidated Administration and Processing of Entries (CAPE) platform inside ACE as the exclusive mechanism for claiming an IEEPA refund (CBP CSMS #68340863). For a DTC apparel brand importing 4 to 8 containers per quarter from Vietnam at the 2025 IEEPA stack, the recoverable amount per container of cut-and-sew product valued at $180K FOB is $18,000 at the 10% rate and $36,000 at the 20% rate, real cash that can fund the next season's inventory. The free ES-003 refund calculator on GingerControl's IEEPA refund service page adds up the IEEPA lines in your ACE export entry by entry, so you and your broker can check the refund before the CAPE Declaration goes up.
Why the IEEPA refund matters more to apparel than almost any other category
Apparel and footwear are the categories where the 2025 IEEPA tariffs collided with margins that were already thin and supply chains that had already shifted out of China.
The data from the past 18 months tells the story. Vietnam's share of US apparel imports rose from 19.1% in June 2024 to 22.1% in July 2025 by value, while China's share fell from 24.6% to 15.6% as the IEEPA reciprocal rates announced in April 2025 (34% on China-origin, 46% on Vietnam-origin) reshaped sourcing decisions (Sheng Lu Fashion data, September 2025). For DTC brands that had already moved production to Vietnam, Bangladesh, or Cambodia precisely to escape Section 301 China duties, the 2025 IEEPA layer was a punch they did not see coming.
That punch is now refundable, with constraints.
| HTS chapter | Category | Top apparel/footwear sourcing | 2025 IEEPA stack |
|---|---|---|---|
| 61 | Knit apparel (T-shirts, hoodies, knit dresses, activewear) | Vietnam, Bangladesh, China, India | MFN 16-32% + IEEPA 10-20% |
| 62 | Woven apparel (denim, button-downs, woven dresses, outerwear) | Vietnam, Bangladesh, Cambodia, China | MFN 8-28% + IEEPA 10-20% |
| 64 | Footwear | Vietnam, China, Indonesia, Cambodia | MFN 0-37.5% + IEEPA 10-20% |
| 50-60 | Textile inputs (yarn, fabric, trims) | China, India, Vietnam, Pakistan | MFN varies + IEEPA 10-20% |
IEEPA here is the reciprocal duty: 10% from April 5, 2025, and from August 7, 20% for Vietnam and Bangladesh and 19% for Cambodia and Indonesia; China-origin goods paid more (see the table below).
A DTC sneaker brand that imported 12,000 pairs per quarter from Vietnam at $35 FOB per pair landed each container at roughly $420K FOB. From August 7, 2025 the IEEPA reciprocal duty on Vietnam was 20% (10% from April 5), on top of an MFN footwear rate that already runs 9 to 20% depending on construction. At 20%, that is a duty bill of roughly $122K to $168K per container, of which the IEEPA portion (the refundable part) is $84,000.
Quotable insight: The 2025 IEEPA tariff did not just cost apparel brands money, it locked their working capital into a duty rate the law has now invalidated. Recovering those entries through CAPE is the difference between holding the next season's launch and pulling SKUs.
The CAPE process, translated for DTC brands
If your brand has never filed anything with CBP directly and your broker handles "all that customs stuff," here is what CAPE actually changes:
CAPE = Consolidated Administration and Processing of Entries. It is a tool inside the ACE Portal, launched April 20, 2026, that handles IEEPA refund requests by CSV upload (CBP IEEPA Refunds Overview, April 2026).
The hard rules:
- Only the IOR or the licensed customs broker who filed the entry can submit a CAPE Declaration. If your brand uses a freight forwarder who arranged the broker, the actual filer of record is the broker. They are the one who uploads.
- Post-summary corrections (PSCs) cannot be used for IEEPA refunds. CAPE is exclusive (Troutman Pepper Locke).
- Phase 1 covers unliquidated entries plus entries within 80 days of liquidation, mapped to the 180-day protest window under 19 U.S.C. § 1514.
- CAPE Declaration cap: 9,999 entry numbers per upload, multiple uploads allowed.
- Refund timeline: 60 to 90 days from acceptance (Forvis Mazars).
- Refund target: the IEEPA Chapter 99 portion of the duty stack only. Section 301 China duties, Section 232, and any AD/CVD remain in place, and the 10% Section 122 surcharge on goods entered from February 24 to July 23, 2026 is not refundable through CAPE either.
Review IEEPA refunds and customer tariff chargebacks against the sales contract when customers originally paid a separately identified tariff surcharge.
For a DTC brand importing 30 to 80 entries per year, your broker can file every eligible entry in a single CAPE Declaration. The administrative cost is low. The cash flow upside is large.
Step by step: what a DTC apparel brand does this week
Step 1: Ask your broker for the 2025 IEEPA Chapter 99 entry list
Email your broker a single sentence: "Please pull every entry summary from 2025 onwards that contains an HTSUS Chapter 99 IEEPA code (the 9903.01 and 9903.02 headings) and tell me which are unliquidated or within 80 days of liquidation."
Most apparel brands will get back a list of 30 to 200 entries depending on volume.
Step 2: Identify which IEEPA codes apply to your goods
The 2025 reciprocal IEEPA tariff codes that hit apparel and footwear most often:
- 9903.01 headings: the 10% reciprocal rate from April 5, 2025 (for these three countries until August 6), and the fentanyl IEEPA tariff on China (an additional layer on top of Section 301)
- 9903.02.69: reciprocal rate on Vietnam (20% from August 7, 2025)
- 9903.02.11: reciprocal rate on Cambodia (19% from August 7, 2025)
- 9903.02.05: reciprocal rate on Bangladesh (20% from August 7, 2025)
If you import from a mix of Vietnam, Bangladesh, China, and Cambodia (typical for a DTC brand running fast fashion or basics across multiple factories), the refund will span multiple Chapter 99 codes at different rates.
Step 3: Reconcile the refund math per entry
For each eligible entry, your refund is the duty paid under the IEEPA Chapter 99 line. This is not the same as the difference between 2025 and current rates, because Section 122 (10%, on goods entered from February 24 to July 23, 2026) was never in place in 2025, and since July 24, 2026 the forced-labor Section 301 applies instead. The IEEPA refund is precisely and only the Chapter 99 IEEPA amount.
For a Vietnamese knit T-shirt entry valued at $90K FOB, entered in September 2025 and classified under HTS 6109.10.0012 (16.5% MFN) plus the 20% IEEPA reciprocal rate:
- MFN duty paid: $90,000 x 16.5% = $14,850
- IEEPA duty paid: $90,000 x 20% = $18,000
- Total duty paid: $32,850
- Refundable through CAPE: $18,000
For a Cambodian woven dress entry valued at $120K FOB, entered in September 2025 and classified under HTS 6204.43.4030 (16% MFN) plus the 19% IEEPA reciprocal rate:
- IEEPA duty paid: $120,000 x 19% = $22,800
- Refundable through CAPE: $22,800
To ballpark the total across all your 2025 containers before your broker reconciles each entry, run them through our free IEEPA tariff refund estimator.
Step 4: Have your broker file the CAPE Declaration
Your broker uploads the CSV. CBP returns acceptance. The 60 to 90 day clock starts.
Step 5: While waiting, recompute current entries against the corrected stack
This is the trap brands fall into. The IEEPA tariff is gone, but Section 301 on China-origin apparel is still here, and since July 24, 2026 the forced-labor Section 301 adds 10% or 12.5% depending on the origin (12.5% for China and Vietnam). GingerControl's Tariff Calculator rebuilds the corrected duty stack per HTS code per origin per entry date so your brand's accounts payable and Shopify Markets pricing both reflect the right number for goods landing in May, June, and July 2026.
Vietnam vs Bangladesh vs Cambodia vs China: where is the refund largest?
| Origin | 2025 IEEPA reciprocal | Typical apparel HTS impact | Refund per $100K FOB entry |
|---|---|---|---|
| Vietnam | 10%, then 20% from August 7, 2025 | Knit (Ch 61), woven (Ch 62), footwear (Ch 64) | $10,000 to $20,000 |
| Cambodia | 10%, then 19% from August 7, 2025 | Mostly woven (Ch 62), some footwear | $10,000 to $19,000 |
| Bangladesh | 10%, then 20% from August 7, 2025 | Knit (Ch 61) heavy, denim (Ch 62) | $10,000 to $20,000 |
| China | Fentanyl 20% plus reciprocal 10% for most of 2025 (125% reciprocal from April 10 to May 13; fentanyl 10% from November 10) | All chapters | About $30,000 for most of 2025 (plus Section 301 still applies separately, not refundable) |
| Indonesia | 10%, then 19% from August 7, 2025 | Footwear (Ch 64) heavy | $10,000 to $19,000 |
Source: Executive Order 14257 (10% from April 5, 2025), Executive Order 14326 (rates from August 7, 2025), and, for China, Executive Order 14298 (reciprocal 10% from May 14, 2025) and Executive Order 14357 (fentanyl 10% from November 10, 2025).
A DTC denim brand splitting production between Vietnam and Bangladesh in 2025 is sitting on a refund pool roughly 40% of its annual customs duty bill, a one-time cash injection that for many brands rivals their entire 2025 marketing budget.
What about brands that ship under DDP or use a 3PL as IOR?
Two structural questions matter for brands that did not file as IOR themselves:
- DDP (Delivered Duty Paid) shipments. If your factory or freight forwarder filed entry as IOR and paid the duty, the IEEPA refund flows back to whoever paid. You will need to negotiate with that party to reclaim the duty portion of your landed cost.
- Third-party importer of record (3PL or 4PL). Same dynamic. The 3PL is the IOR. They will receive the refund. Most reputable cross-border 3PLs are passing IEEPA refunds back to their merchants pro rata, but you should confirm in writing.
For courier-delivered DDP goods, resolve IEEPA refund ownership on DDP courier shipments from the entry record before assuming the buyer can file.
This is one of the cleanest reasons for DTC brands to be the IOR on their own entries going forward. Section 122 has come and gone (the forced-labor Section 301 replaced it on July 24, 2026), and any future tariff event will hit the IOR first.
How does the GingerControl approach compare to spreadsheet refund tracking?
| Approach | Date-aware MFN + Section 122 + Chapter 99 stack | Per-entry refund delta export | Multi-origin reconciliation in one view | Best suited for |
|---|---|---|---|---|
| GingerControl (Tariff Calculator, plus the free ES-003 refund calculator) | Yes, the Tariff Calculator prices the layers in force on the entry date across 200+ origins | The ES-003 refund calculator totals the IEEPA duty on each entry from your ACE export; no export per CAPE Declaration line | Yes, every origin in your ES-003 in one view | DTC brands with multi-origin sourcing and 30-200 entries per year |
| Broker spreadsheet | Manual, accuracy depends on broker | Manual | One spreadsheet per origin typically | Brands with single-origin sourcing |
| ACE entry summary export | No, ACE shows what was paid only | No | Filterable but no math | Pulling raw 2025 IEEPA exposure |
| In-house duty model | If you have an engineer | Depends | Depends on tooling | Brands with internal trade compliance hire |
Bottom line: For DTC apparel and footwear brands sourcing across Vietnam, Bangladesh, Cambodia, China, and Indonesia, the date-sensitive layering of IEEPA, Section 122, and Section 301 makes refund reconciliation a math problem that spreadsheets get wrong by entry. GingerControl fits when you need per-entry numbers your broker can tie back to the CAPE Declaration: the free ES-003 refund calculator totals the IEEPA duty on each entry, and the Tariff Calculator prices the layers that stay after the refund. A broker spreadsheet works if you only source from one country and your entry count is under 30.
What apparel brands should NOT expect from CAPE
- Section 301 China duties remain. If you ship from China, the 7.5 to 25% Section 301 layer your brand has paid for years is still there. Not refundable through CAPE.
- Section 122 is not refunded through CAPE, and it is over. It applied at 10% to goods entered from February 24 to July 23, 2026; since July 24, the forced-labor Section 301 applies instead (10% or 12.5% by origin).
- Antidumping orders on quilts, mattress covers, and certain home textiles remain. Separate authority.
- MFN base rate remains. Apparel has never been duty-free.
- Brokers cannot file for entries they did not originally file. If you switched brokers in late 2025, the original filing broker has to upload the CAPE Declaration for entries they handled.
FAQ
My DTC brand has never filed anything with CBP directly. Can I still get an IEEPA refund?
Yes. Your existing customs broker (the one whose filer code is on your 2025 entry summaries) can upload the CAPE Declaration on your behalf. You do not need to log into ACE yourself. For DTC apparel brands importing 4 to 12 containers per quarter from Vietnam, Bangladesh, or China, the free ES-003 refund calculator on GingerControl's IEEPA refund service page gives you a per-entry refund estimate in dollars from your own ACE export, so you can hold your broker accountable for the CAPE filing math.
What if my brand uses a 3PL as Importer of Record? Do I still get the refund?
The refund flows to whoever was the IOR on the entry. If a 3PL or freight forwarder was the IOR, they receive the refund and decide how to pass it back. Most cross-border 3PLs are passing it through pro rata, but you should confirm in writing. Ask the 3PL for the entry summaries behind your shipments: the IEEPA Chapter 99 lines on each one (9903.01 and 9903.02) show exactly what was paid, so you can verify the number it hands back.
How much could a Vietnam apparel brand actually recover?
Vietnam paid a 10% IEEPA reciprocal rate from April 5, 2025 and 20% from August 7 on top of MFN, which for knit and woven apparel runs 16 to 32% (Sheng Lu Fashion data). For a brand importing $1.2M per quarter FOB Vietnam, the IEEPA-only portion is $120,000 to $240,000 per quarter, all refundable if the entries are inside Phase 1 of CAPE. GingerControl's Tariff Calculator confirms the per-entry math against the actual HTS lines.
For garments or fabric products, use textile and apparel HTS classification to check fiber content, construction and the applicable notes.
Does my brand have to wait for Phase 2 to refund anything from early 2025?
No. Phase 2, deployed June 29, 2026, only added reconciliation-flagged entries with no reconciliation entry on file. Early-2025 entries that liquidated more than 80 days ago are outside CAPE for importers who did not sue: within 180 days of liquidation the route is a protest under 19 U.S.C. § 1514, after that a suit at the Court of International Trade, and since October 6, 2026 CAPE Phase 3 processes finally liquidated entries of plaintiffs whose reliquidation the court has ordered (CBP IEEPA FAQ; CBP declaration to the CIT, October 6, 2026). For brands sitting on early-2025 entries already liquidated, GingerControl's free Policy Briefings send one email when CBP or another agency changes a U.S. trade rule.
Use the CIT litigation versus CAPE for IEEPA refunds comparison when an entry falls outside the available administrative refund route.
What documents does my broker need to file the CAPE Declaration?
The entry summary, the original commercial invoice, and the entry's Chapter 99 IEEPA HTSUS line items. Most brokers already have these in their entry archive. If your brand keeps an internal duty record (recommended), the free ES-003 refund calculator on GingerControl's IEEPA refund service page totals the IEEPA lines per entry from your own ACE export, which you can keep with that record.
Can I use the IEEPA refund to offset duty on entries landing in May or June 2026?
No. The CAPE refund is paid out as a separate disbursement, not credited against future duty. Future entries pay MFN plus any surviving Chapter 99 lines, such as Section 301 on China and, since July 24, 2026, the forced-labor Section 301 (10% or 12.5% by origin). GingerControl's Tariff Calculator computes the corrected stack for current entries so your accounts payable and your Shopify Markets pricing both reflect the right number.
Do I need to file separately for footwear vs apparel entries?
No. A single CAPE Declaration can contain footwear (Chapter 64) and apparel (Chapters 61, 62) entries together, as long as each entry contains a valid IEEPA Chapter 99 line. Your broker handles the CSV format. To audit footwear and apparel refund pools separately for finance, sort your ES-003 lines by HTS chapter (64 versus 61 and 62) and total the 9903.01 and 9903.02 duty on each side.
For shoes, Chapter 64 footwear HTS classification starts with upper material, sole material and the applicable value tests.
Reclaim what was overcharged, then keep the corrected math accurate
The IEEPA refund recovers your 2025 overpayment. The longer-term lever is making sure every 2026 entry lands at the corrected duty rate, with no accidental IEEPA layering. GingerControl's Tariff Calculator rebuilds the full US duty stack (MFN, Section 301 including the forced-labor duties, Section 232, other Chapter 99 lines) for any apparel HTS code, any country, any entry date, with the date-sensitive logic DTC brands need across multi-origin sourcing. Try the Tariff Calculator.
The Tariff Calculator is part of GingerLite, the GingerControl app for brokers and small businesses: $150 a month for 300 credits, and each run uses credits. Book a call.
References
- U.S. Customs and Border Protection, IEEPA Duty Refunds program page
Source: CBP IEEPA Duty Refunds - CBP Cargo Systems Messaging Service, CSMS #68340863 UPDATE on CAPE for IEEPA Refunds
Source: CSMS #68340863 GovDelivery bulletin
Published: April 2026 - U.S. Customs and Border Protection, IEEPA Refunds Overview Webinar Slides
Source: CBP webinar deck PDF, April 17, 2026 - U.S. Customs and Border Protection, IEEPA Frequently Asked Questions
Source: CBP IEEPA FAQ - Sheng Lu Fashion / FASH455, Patterns of US Apparel Imports, September 2025
Data cited: Vietnam share rose to 22.1%, China share fell to 15.6%, Vietnam apparel imports up 12.5% in July 2025
Source: Sheng Lu Fashion data - Sheng Lu Fashion / FASH455, Average Tariff Rates for US Apparel Imports under Reciprocal Tariff Policy, July 2025
Data cited: MFN rates by chapter, IEEPA reciprocal rates by origin
Source: Sheng Lu Fashion tariff rate analysis - Suaid Global: US Tariffs 2026: Section 301, IEEPA, 232 Guide
Data cited: Country-by-country IEEPA reciprocal rates and post-ruling status
Source: Suaid Global tariff guide - ExFreight, IEEPA Reciprocal Tariffs 2025-2026: Country Rates and Importer Guide
Source: ExFreight tariff guide - Troutman Pepper Locke, CBP Issues Guidance on IEEPA Duty Refunds via New CAPE Process
Source: Troutman Pepper Locke insight, April 2026 - Forvis Mazars US, IEEPA Tariff Refund Update: CAPE System and Processing Guidance
Data cited: 60-90 day refund processing timeline
Source: Forvis Mazars insight, April 2026 - U.S. Court of International Trade, Freestyle World, Inc. v. U.S. Customs and Border Protection, No. 26-01088, Opinion and Order, October 8, 2026
Data cited: CBP's estimate of about $166 billion in IEEPA duties on 53 million entries by roughly 330,000 importers of record
Source: CIT Slip Op., Freestyle World, ECF No. 61
Related industries
For the full 2026 duty stack, recovery levers, and FAQs for this sector, see the Apparel & Footwear industry guide.
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Reviewed by Michael Weick, LCB / CCS
