Furniture Importer IEEPA Refund Guide: CAPE Filing Steps

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 and kitchen cabinets (25%, set to rise to 30% and 50% on January 1, 2027) is not.

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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, with the step-up delayed to January 1, 2027 by Proclamation 11000 (DFDL trade alert):

• Upholstered wooden furniture, from every country: 25% Section 232 (effective October 14, 2025), set to rise to 30% on January 1, 2027
• Kitchen cabinets and bathroom vanities, from every country: 25% Section 232, set to rise to 50% on January 1, 2027
• Caps and the reciprocal duty: the UK pays 10%, and the EU, Japan, South Korea and Taiwan a combined 15%; goods under these Section 232 duties stopped paying the IEEPA reciprocal duty and the Canada and Mexico fentanyl duties from October 14, 2025, though China's fentanyl duty still applied (Proclamation 10976)

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.

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Where US furniture comes from, and what 2025 cost importers

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

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, which had no Section 301 and, outside upholstered wooden furniture and cabinets from October 14, 2025, no Section 232 to compete for the duty share.

Quotable insight: A furniture importer landing 12 forty-foot containers of Vietnamese metal-frame upholstered seating per quarter at $90K FOB each paid $108,000 a quarter in IEEPA duties at the 10% rate, and $216,000 at the 20% rate from August 7, 2025, 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.

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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 furniture in 2025 (20%, then 10% from November 10) and on Mexico furniture not entered under USMCA (25%)
• 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 wooden furniture (25%, rising to 30% on January 1, 2027)
• Section 232 on kitchen cabinets and vanities (25%, rising to 50% on January 1, 2027)
• Section 301 China duties (separate authority, still in force on most Chapter 94 lines from China)
• Section 122 surcharge at 10% (separate authority; it applied only to entries from February 24 to July 23, 2026 and expired July 24, 2026)
• 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)

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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 wooden-frame seat (HTS 9401.61.4011) from China entered in late 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% from October 14, 2025 on upholstered wooden furniture, not refundable)
• IEEPA Chapter 99 fentanyl (10% from November 10, 2025, refundable); no IEEPA reciprocal line, because Section 232 wood products were exempt from it
• Section 122 (not on this entry: it applied only to entries from February 24 to July 23, 2026, at 10%, and is not refunded through CAPE)

Only the IEEPA Chapter 99 line goes into the CAPE Declaration. The Section 232 and Section 301 lines stay paid. To ballpark just the refundable IEEPA-only portion across your entries (setting the Section 232 upholstery and cabinet layers aside), start with our free IEEPA tariff refund estimator.

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. The free ES-003 refund calculator on GingerControl's IEEPA refund service page reads your ACE export line by line and counts only the 9903.01 and 9903.02 lines as IEEPA, so the Section 232 and Section 301 lines on the same entry (still owed) stay out of the refund figure. When CBP asks about an entry during the processing window, the answer sits on that entry's own lines.

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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.

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 on metal-frame seating, casegoods and mattresses: 10% to 20% 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 step-up set for January 1, 2027 is the bigger ongoing line item ahead.

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

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 fits when you need to show which dollars are refundable and which stay owed: the free ES-003 refund calculator counts only the IEEPA lines, and the Tariff Calculator prices the layers that stay. A broker spreadsheet is workable for Vietnam-only sourcing with no Section 232 in the picture.

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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 stays at 25% until January 1, 2027, when it is set to rise to 30% on upholstery and 50% on cabinets. Not refundable.
• Section 301 on China-origin Chapter 94 entries remains. Still in force.
• Section 122 is not part of CAPE. Its 10% surcharge applied to most origins only from February 24 to July 23, 2026; since July 24, 2026, Section 301 duties of 10% or 12.5% on products of 60 economies took its place.
• 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.

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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. The CAPE CSV lists entry numbers only, and ACE removes the IEEPA Chapter 99 lines itself, so no Section 232 dollars ride along; the free ES-003 refund calculator shows in advance how much of each entry is IEEPA.

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

Vietnam paid a 10% IEEPA reciprocal rate from April 5, 2025 and 20% from August 7 (the 46% announced in April applied only on April 9). For an importer landing $4M FOB per quarter from Vietnam, the IEEPA-only portion is $400,000 to $800,000 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 reciprocal layer. The free ES-003 refund calculator totals the IEEPA lines entry by entry, 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 wooden furniture, from China or anywhere else, still pays the Section 232 rate (25%, set to rise to 30% on January 1, 2027), and kitchen cabinets and vanities still pay 25%, set to rise to 50% on the same date (DFDL trade alert). They cannot slip into the refund: ACE removes only the IEEPA Chapter 99 lines from the entries on a CAPE Declaration.

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

CAPE does not cover it unless you sued. Phase 1 stops 80 days after liquidation, and Phase 2, deployed June 29, 2026, only added reconciliation-flagged entries. 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 furniture importers sitting on liquidated Q1 2025 entries, GingerControl's free Policy Briefings email you when CBP announces a change like this, 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 free Policy Briefings email you when CBP changes the timeline.

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. Ask the forwarder for the entry summaries behind your shipments: the IEEPA Chapter 99 lines on each one (9903.01 and 9903.02) are the refund you should see passed back.

For courier-delivered DDP goods, resolve IEEPA refund ownership on DDP courier shipments from the entry record before assuming the buyer can file.

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. The free ES-003 refund calculator reads every chapter in your export the same way, by the Chapter 99 number on each line, so the refund reconciliation stays consistent.

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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 at 25% until January 1, 2027, when it is set to rise to 30% and 50%, and, since July 24, 2026, the forced-labor Section 301 on furniture outside Section 232 in place of the expired Section 122. GingerControl's Tariff Calculator rebuilds the full US duty stack (MFN, Section 232, Section 301 and other Chapter 99 lines, with Section 122 for entries in its window) for any furniture HTS code, any country, any entry date, separating refundable from non-refundable layers per line. Try the Tariff Calculator.

GingerControl builds GingerOS, the AI trade compliance platform that runs on your process and the data you have, ERP or not. A project starts with Prototype Week, the step before a quote. Talk to our team.

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References

1. U.S. Customs and Border Protection, IEEPA Duty Refunds program page
   Source: CBP IEEPA Duty Refunds
2. CBP Cargo Systems Messaging Service, CSMS #68340863 UPDATE on CAPE for IEEPA Refunds
   Source: CSMS #68340863 GovDelivery bulletin
   Published: April 2026
3. U.S. Customs and Border Protection, IEEPA Refunds Overview Webinar Slides
   Source: CBP webinar deck PDF, April 17, 2026
4. U.S. Customs and Border Protection, IEEPA Frequently Asked Questions
   Source: CBP IEEPA FAQ
5. Holland & Knight, Court of International Trade Orders Nationwide Tariff Refunds
   Data cited: Supreme Court ruling and the CIT's nationwide refund order
   Source: Holland & Knight insight, March 2026
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
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
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
9. Troutman Pepper Locke, CBP Issues Guidance on IEEPA Duty Refunds via New CAPE Process
   Source: Troutman Pepper Locke insight, April 2026
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

Related industries

For the full 2026 duty stack, recovery levers, and FAQs for this sector, see the Furniture & Home Goods industry guide.

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