Furniture Importer IEEPA Refund Guide: CAPE Filing Steps

How can a furniture importer claim an IEEPA tariff refund?

A furniture importer 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 duty (Vietnam at 46%, China at 34%) and is still inside Phase 1's 80-day liquidation window. The Section 232 layer on upholstered furniture and kitchen cabinets is not refundable.

Which furniture entries are eligible for the IEEPA refund?

Phase 1 of CAPE covers any HTS Chapter 94 (or related Chapter 44 wood furniture) entry that contains an IEEPA Chapter 99 reciprocal-tariff line and is unliquidated or within 80 days of liquidation. The Chapter 99 IEEPA portion is refundable; the surviving Section 232 layer on upholstery (30%) and kitchen cabinets (50%) is not.

TL;DR

The Supreme Court's February 20, 2026 decision in Learning Resources, Inc. v. Trump invalidated the IEEPA reciprocal tariffs that hit furniture importers hardest in 2025: Vietnam at 46% and China at 34% on top of an MFN base that for most Chapter 94 lines runs zero (Holland & Knight). On April 20, 2026, CBP launched the Consolidated Administration and Processing of Entries (CAPE) platform inside ACE as the only mechanism for filing an IEEPA refund (CBP CSMS #68340863). For a mid-sized furniture importer landing 8 to 20 forty-foot containers per month from Vietnam (the largest single source of US furniture at $7.45B annually) at the 2025 IEEPA stack, the recoverable amount per container of upholstered seating valued at $90K FOB is roughly $41K, large enough that finance teams need a defensible per-entry calculation. GingerControl's Tariff Calculator rebuilds the corrected duty stack across IEEPA (refundable), Section 232 (still in force on upholstery and cabinets), and Section 122 (10 to 15% baseline) so the CAPE Declaration math reconciles.

Last updated: May 2026

The furniture trade is uniquely complicated by Section 232 on top of IEEPA

Furniture importers are in a different position from apparel or food importers because of one fact: Section 232 tariffs on furniture are still in force, and they are escalating.

Per the October 2025 executive action and the January 1, 2026 step-up (DFDL trade alert):

Upholstered furniture from China: 25% Section 232 (effective October 14, 2025), increased to 30% on January 1, 2026
Kitchen cabinets and bathroom vanities from China: 25% Section 232, increased to 50% on January 1, 2026

These Section 232 layers were authorized under a separate statute (Trade Expansion Act of 1962, Section 232) and were not invalidated by the Supreme Court. The CAPE refund does not touch them.

That distinction is the entire trick to filing a clean Furniture-category CAPE Declaration. The IEEPA portion is refundable. The Section 232 portion stays paid. Mixing them up causes CBP to reject the Declaration, or worse, accept it and then pull it back with interest during the 60-to-90-day verification window.

Where US furniture comes from, and what 2025 cost importers

Vietnam and China together account for the majority of US furniture imports:

Origin	2024 furniture import value	2025 IEEPA reciprocal	Section 232 layer (specific subcategories)
Vietnam	$7.45B (largest single source)	46%	None
China	$5.72B (second largest)	34% (IEEPA fentanyl)	25-30% upholstery, 25-50% cabinets/vanities
Mexico	Significant for casegoods	25% (IEEPA fentanyl)	None
Indonesia	Wood furniture	Reciprocal varied	None
Malaysia	Wood, rattan	Reciprocal varied	None

Source: Furniture trade volumes from Home Furnishings Association and Vietnam supply data via GovFacts trade policy analysis.

For most furniture HTS lines under Chapter 94 (seats, mattresses, lighting, casegoods), the MFN base rate runs from zero (free) to 7.5%. That means in 2025, the IEEPA layer was the dominant component of the duty bill, particularly for Vietnam-origin product where there is no Section 301 and no Section 232 to compete for the duty share.

Quotable insight: A furniture importer landing 12 forty-foot containers of Vietnamese upholstered seating per quarter at $90K FOB each paid roughly $497K in IEEPA duties per quarter that the law has now invalidated. The CAPE refund is not a discretionary opportunity, it is recoverable working capital that the finance team should be quantifying this month.

What CAPE actually does (and does not) cover for furniture entries

CAPE = Consolidated Administration and Processing of Entries. Launched by CBP on April 20, 2026 as the exclusive channel for IEEPA refund requests (CBP IEEPA Refunds Overview, April 2026).

What CAPE refunds for furniture importers:

IEEPA Chapter 99 reciprocal duty paid on Vietnam, Cambodia, Indonesia, Malaysia furniture in 2025 (rates varied by Chapter 99 code)
IEEPA Chapter 99 fentanyl duty paid on China and Mexico furniture in 2025 (25-34%)
Any IEEPA Chapter 99 line on entries that are unliquidated or within 80 days of liquidation

What CAPE does not refund:

Section 232 on upholstered furniture from China (25% then 30%)
Section 232 on kitchen cabinets and vanities from China (25% then 50%)
Section 301 China duties (separate authority, still in force on most Chapter 94 lines from China)
Section 122 reciprocal at 10 to 15% (separate authority, still in force)
MFN base rate (always paid)

The hard rules (Troutman Pepper Locke):

Filer: IOR or licensed customs broker who filed the entry
PSCs are not allowed. CAPE is the only path.
CSV upload format, max 9,999 entry numbers per Declaration, multiple Declarations allowed
Phase 1 eligibility: unliquidated entries plus entries within 80 days of liquidation
Refund timeline: 60 to 90 days from acceptance (Forvis Mazars)

Step by step: what a furniture importer should do this week

Step 1: Pull the 2025 entry list, filtered by Chapter 94 and Chapter 99

Ask your broker for every 2025 entry summary that contains both an HTS Chapter 94 (or 44 wood furniture) line and an HTSUS Chapter 99 IEEPA line. For most furniture importers, this will be the bulk of the 2025 entry log.

Step 2: Separate the IEEPA portion from the Section 232 portion line by line

This is the step that makes furniture refund filings harder than other categories. For an upholstered seat HTS 9401.71.0010 from China imported in November 2025, the entry summary will show:

MFN base rate (low or zero on most Ch 94)
Section 301 (still in force, not refundable)
Section 232 (25% in 2025 on upholstered furniture, not refundable)
IEEPA Chapter 99 fentanyl (34%, refundable)
Section 122 (10% then 15% from late February 2026, not refundable, was not present early 2025)

Only the IEEPA Chapter 99 line goes into the CAPE Declaration. The Section 232 and Section 301 lines stay paid.

Step 3: Filter to Phase 1 eligibility

For each entry, check:

Liquidation date present and within 80 days of today: eligible
Liquidation date null (still unliquidated): eligible
Liquidation date present and more than 80 days ago: not eligible in Phase 1

For furniture importers with typical 30-to-40-day transit and 314-day liquidation, most April through December 2025 entries are still in scope.

Step 4: Build the CAPE Declaration CSV

Per-entry, per-IEEPA-line. Your broker uploads. CBP returns acceptance. The 60 to 90 day refund clock starts.

Step 5: Run a parallel reconciliation in a duty-stack tool

This is the audit trail finance teams want. GingerControl's Tariff Calculator rebuilds the corrected duty stack per HTS line per origin per entry date, separating IEEPA (refundable) from Section 232 (still owed) from Section 301 (still owed) from Section 122 (still owed). The export ties each refund line back to a defensible calculation, so when CBP requests verification during the processing window, the answer is one click away.

Vietnam vs China: where is the recoverable amount actually largest?

This is the question every furniture importer wants answered. The answer depends on whether you ship upholstery, casegoods, kitchen cabinets, or lighting.

Origin and category	2025 IEEPA recoverable	2025 Section 232 (not recoverable)	Net IEEPA refund per $100K FOB
Vietnam upholstered seating (HTS 9401.71)	46%	0%	$46,000
Vietnam wood casegoods (HTS 9403.50)	46%	0%	$46,000
Vietnam mattresses (HTS 9404.21)	46%	0%	$46,000
China upholstered seating (HTS 9401.71)	34%	25% (now 30%)	$34,000
China kitchen cabinets (HTS 9403.40)	34%	25% (now 50%)	$34,000
China casegoods non-upholstered (HTS 9403.30)	34%	0% (no 232 yet on this subcategory)	$34,000
Mexico casegoods	25%	0%	$25,000

For a furniture importer that pivoted heavily to Vietnam in 2024 and 2025 to escape Section 301 China duties, the IEEPA refund is unusually clean: full 46% recoverable per $100K FOB with no offsetting non-refundable layer competing for the duty share. For an importer still anchored in China-origin upholstery, the IEEPA refund is still material but the Section 232 escalation in January 2026 is now the bigger ongoing line item.

How does the GingerControl approach compare to broker-only refund tracking?

Approach	Separates IEEPA from Section 232 / 301 per line	Date-aware Section 122 layering	Per-entry refund delta export	Best suited for
GingerControl Tariff Calculator	Yes, per HTS line per entry	Yes, entry-date sensitive	Yes, exportable per CAPE Declaration line	Furniture importers with mixed Vietnam + China + Mexico sourcing and Section 232 exposure
Broker spreadsheet	Manual, brokers vary in rigor	Manual	Manual, depends on broker template	Single-origin importers with low entry counts
ACE entry summary export	Shows what was paid only	No	No, lookup only	Pulling raw 2025 IEEPA exposure
ERP duty module	If configured for US tariff stack	Depends on integration	Depends	Larger furniture importers with SAP / NetSuite integration

Bottom line: For furniture importers landing 5+ containers per month with any China-origin upholstery or cabinet exposure, the Section 232 escalation makes line-by-line separation of IEEPA versus non-IEEPA non-negotiable for CAPE filing accuracy. GingerControl's Tariff Calculator is the right fit when you need to prove which dollars are refundable and which stay owed. A broker spreadsheet is workable for Vietnam-only sourcing with no Section 232 in the picture.

What furniture importers should NOT expect from the IEEPA refund

Section 232 on upholstered furniture and kitchen cabinets is here to stay, and the rate stepped up January 1, 2026 (30% on upholstery, 50% on cabinets). Not refundable.
Section 301 on China-origin Chapter 94 entries remains. Still in force.
Section 122 reciprocal at 10 to 15% remains. Applies to most origins.
AD/CVD on certain wooden bedroom furniture from China remains. This order has been in place since 2005.
PSCs do not work for IEEPA refunds. CAPE is exclusive.
You cannot use the IEEPA refund to net against future duty. The refund is paid as a separate disbursement.

FAQ

My furniture brand sources from both Vietnam and China. Do I file one CAPE Declaration or two?

You can include both in a single CAPE Declaration as long as each entry contains a valid IEEPA Chapter 99 line. The CSV format separates per entry, not per origin. For furniture importers with mixed Vietnam and China sourcing, the harder problem is separating the refundable IEEPA portion from the non-refundable Section 232 portion on China upholstery and cabinets. GingerControl's Tariff Calculator splits this out per HTS line so your broker uploads only the IEEPA dollars.

How much can a Vietnam-origin furniture importer actually recover?

Vietnam paid the 46% IEEPA reciprocal rate in 2025. For an importer landing $4M FOB per quarter from Vietnam, the IEEPA-only portion is roughly $1.84M per quarter, all refundable through CAPE if entries are inside Phase 1. Vietnam supplies $7.45B in furniture to the US annually (Home Furnishings Association), and most of that paid the 46% layer. GingerControl's Tariff Calculator computes the corrected duty stack so the refund pool is defensible per entry.

Does the IEEPA refund cover Section 232 tariffs on Chinese upholstered furniture?

No. Section 232 was authorized under the Trade Expansion Act of 1962 and is entirely separate from IEEPA. Upholstered furniture from China still pays the Section 232 rate (25% in 2025, 30% from January 1, 2026), and kitchen cabinets and vanities still pay 25% rising to 50% (DFDL trade alert). GingerControl's Tariff Calculator separates these layers per line so you do not accidentally include them in the CAPE Declaration.

What if my entry was already liquidated more than 80 days ago?

Phase 1 of CAPE does not cover it. Those entries fall outside the 180-day protest window under 19 U.S.C. § 1514. CBP has signaled a Phase 2 may handle older liquidated entries, but no date is committed (CBP IEEPA FAQ). For furniture importers sitting on liquidated Q1 2025 entries, GingerControl's Tariff Briefing tracks Phase 2 progress directly from CBP's CSMS messages so you know when filing opens.

How long until the refund actually hits my account?

CBP has committed to 60 to 90 days from acceptance of the CAPE Declaration to refund payment, absent a compliance review (Forvis Mazars). For a furniture importer who files a Phase 1 Declaration in mid-May covering 240 entries, refund payment should land between mid-July and mid-August. GingerControl's Tariff Briefing flags any timeline shifts CBP issues.

Can my freight forwarder file the CAPE Declaration if they were the IOR?

Only the IOR or the licensed customs broker who filed the original entry can submit the Declaration. If your freight forwarder acted as IOR or arranged the broker who filed, the refund flows back to whoever was IOR on the entry. Most reputable forwarders are passing IEEPA refunds back to the merchant pro rata, but you should confirm in writing. GingerControl's Tariff Calculator gives you an independent per-entry refund estimate so you can verify what your forwarder hands back.

Do I have to file separately for wood furniture (Chapter 44) and upholstered furniture (Chapter 94)?

No. A single CAPE Declaration can contain entries across Chapter 94, Chapter 44, Chapter 73 (metal furniture), and Chapter 95 (lighting and decorative goods) as long as each entry contains a valid IEEPA Chapter 99 line. The CSV is per entry, not per chapter. GingerControl's Tariff Calculator handles all furniture-related chapters in one workspace so the refund reconciliation is consistent.

Recover what was overpaid, and stop overpaying on the corrected stack

The IEEPA refund returns 2025 cash. The bigger ongoing lever is making sure 2026 entries land at the corrected stack, with Section 232 on upholstery and cabinets now stepped up and Section 122 still applied. GingerControl's Tariff Calculator rebuilds the full US duty stack (MFN, Section 122, Section 232, Section 301, Chapter 99) for any furniture HTS code, any country, any entry date, separating refundable from non-refundable layers per line. Try the Tariff Calculator.

GingerControl is not just a tool. We work with furniture importers and home goods brands on broker workflow audit, IOR strategy, and end-to-end custom duty-stack systems for high-volume cross-border operations. Talk to our team.

References

[REF 1] U.S. Customs and Border Protection — IEEPA Duty Refunds program page Source: CBP IEEPA Duty Refunds

[REF 2] CBP Cargo Systems Messaging Service — CSMS #68340863 UPDATE on CAPE for IEEPA Refunds Source: CSMS #68340863 GovDelivery bulletin Published: April 2026

[REF 3] U.S. Customs and Border Protection — IEEPA Refunds Overview Webinar Slides Source: CBP webinar deck PDF, April 17, 2026

[REF 4] U.S. Customs and Border Protection — IEEPA Frequently Asked Questions Source: CBP IEEPA FAQ

[REF 5] Holland & Knight — Court of International Trade Orders Nationwide Tariff Refunds Data cited: $166 billion collected from 330,000+ businesses, Supreme Court ruling Source: Holland & Knight insight, March 2026

[REF 6] DFDL — New US Tariffs on Asian Furniture, Trucks, Pharma October 2025 Update and Compliance Guide Data cited: Section 232 rates on upholstered furniture (25 to 30%) and kitchen cabinets (25 to 50%) Source: DFDL trade alert, October 2025

[REF 7] Home Furnishings Association — The Impact of Vietnam Trade Tariffs on the Furniture Industry Data cited: Vietnam $7.45B, China $5.72B furniture import volumes Source: Home Furnishings Association blog

[REF 8] GovFacts — What the Tariff Delay on Furniture Means for Prices and Trade Talks Data cited: Vietnam supplies $7.45B annually, China supplies $5.72B Source: GovFacts trade policy analysis

[REF 9] Troutman Pepper Locke — CBP Issues Guidance on IEEPA Duty Refunds via New CAPE Process Source: Troutman Pepper Locke insight, April 2026

[REF 10] 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