Recover IEEPA Duties Paid on Vietnamese Imports

Vietnam: The Second-Largest IEEPA Tariff Exposure

Vietnam became one of the most significant IEEPA tariff targets as U.S. importers had shifted supply chains from China. Tariff rates on Vietnamese goods reached 46% on a wide range of HTS categories — hitting importers of apparel, footwear, consumer electronics, furniture, and seafood particularly hard.

The Federal Circuit’s ruling covers all IEEPA tariff orders, including those applied to Vietnamese-origin goods. If your company imported from Vietnam during the tariff period, your refund claim is eligible for processing under CAPE — and Phase 3, which opened October 6, 2026, now includes finally liquidated entries.

Top Import Categories Affected

• Apparel, clothing, and textiles (HTS Chapters 61–63)
• Footwear (HTS Chapter 64)
• Furniture and bedding (HTS Chapter 94)
• Consumer electronics and components (HTS Chapters 84–85)
• Seafood and processed food products (HTS Chapter 16)
• Plastics, rubber, and packaging materials
• Bags, luggage, and travel goods (HTS Chapter 42)
• Bicycle frames and sporting goods (HTS Chapter 95)

Key Issues for Vietnam Importers

China-to-Vietnam Supply Chain Shifts

Many importers who moved production from China to Vietnam during 2023–2025 face a country-of-origin review. CBP scrutinized whether goods manufactured in Vietnam using Chinese inputs had undergone a substantial transformation sufficient to confer Vietnamese origin. If CBP issued a negative ruling on country of origin, the entry may have been assessed under both Vietnamese and Chinese IEEPA tariff rates — and both are refundable under the court order.

Section 321 and De Minimis Entries

Some Vietnamese goods were imported under de minimis thresholds or Section 321 administrative exemptions. These entry types have different CAPE filing pathways and documentation requirements. We identify which of your entries fall in this category and route them correctly.

Bonded Manufacturers and CMT Arrangements

If your goods were produced under a Cut-Make-Trim arrangement or from a bonded manufacturer in Vietnam, the duty calculation and refund eligibility may turn on whether the importer of record had a valid binding ruling in place. We review all bonded manufacturer documentation as part of the audit.

Our Vietnam Refund Recovery Process

Step 1: Entry Audit by HTS and Origin

We pull all entry summaries for Vietnamese-origin goods and cross-reference them against the IEEPA tariff order schedules. We flag any entries with mixed-origin components or origin disputes for additional review before filing.

Step 2: Liquidation Classification

Entries are sorted by liquidation status — finally liquidated, unliquidated, or under protest. Each bucket routes to a different CAPE phase or CBP filing track. Misrouting is the most common reason Vietnam importer claims are delayed.

Step 3: CAPE Submission

All filings are coordinated with or executed through a licensed customs broker in accordance with 19 C.F.R. Part 111. We prepare the complete submission package and manage all CBP correspondence through disbursement.