Vietnam-origin goods carried a sustained 20% IEEPA tariff rate — after a 46% rate was threatened but never took effect — during 2025. The Supreme Court ruled those duties unlawful, and CBP's CAPE system is processing refunds now. With a new 12.5% Section 301 duty on Vietnamese goods now in effect, recovering your IEEPA overpayments before your duty stack gets more complex is more urgent than ever.
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The Supreme Court’s February 20, 2026 ruling in Learning Resources v. Trump held that IEEPA tariffs were unlawful, opening an estimated $166 billion in refunds across roughly 53 million entry summaries and 330,000 importers of record. U.S. importers of Vietnam-origin goods are among the eligible. CBP’s CAPE system has been processing refunds through Phase 1 and Phase 2, and the finally-liquidated Phase 3 is now underway on a limited, litigated basis. For current claim and disbursement totals, CBP’s IEEPA Duty Refunds page is the authoritative source — the figures move with each court filing.
Vietnam is the second-largest source of U.S. apparel imports after China. A sustained 20% IEEPA rate on top of existing MFN duties created significant duty exposure — and correspondingly meaningful refund potential per entry.
Vietnam's growing electronics manufacturing sector — including Samsung facilities producing smartphones and consumer electronics — generated significant IEEPA duty payments at the sustained 20% rate.
Vietnam is the largest single-country source of U.S. furniture imports. High-volume, high-value entries with 20% IEEPA exposure and strong aggregate refund potential.
Vietnam's shrimp, fish, and seafood exports to the U.S. carry IEEPA duty exposure. Processors and importers in the seafood supply chain paid significant duties at the sustained 20% rate.
CBP is processing IEEPA refunds in three phases. Your eligibility depends on your entry liquidation status and whether a Type 09 reconciliation entry has been filed. Phase status and eligibility are actively evolving through ongoing CIT litigation.
Entries not yet liquidated, or liquidated within 80 days of your CAPE Declaration filing date. Open since April 20, 2026. Applies to all origins including Vietnam.
Entry Types 01, 02, 06 flagged for reconciliation with no Type 09 filed. Open since June 29, 2026. File CAPE Declaration before Type 09 — sequence matters.
Entries liquidated more than 80 days ago. The CIT has begun ordering reliquidation, but under the government’s current position — now on appeal at the Federal Circuit — Phase 3 refunds reach only importers who filed individual CIT lawsuits (roughly 3,700 cases). Eligibility for non-litigants remains unresolved.
From eligibility screening to CAPE Declaration delivery — TariffIQ™ handles the analysis, we prep the filing, your licensed broker submits in ACE.
Submit your import profile at tariffbureau.com/assessment. TariffIQ™ screens your Vietnam-origin entries, HTS codes, and liquidation status against CAPE Phase 1, 2, and 3 eligibility criteria. No obligation.
We build a CFO-ready financial model of your recoverable Vietnam-origin IEEPA duties plus statutory interest under 19 U.S.C. § 1505. You see your recovery estimate before signing anything.
We build your CAPE Declaration CSV, validate Chapter 99 HTS codes on your Vietnam-origin entries, check ACH enrollment status in ACE, and verify filing sequence. Your licensed customs broker submits in ACE.
No recovery, no fee. We take a percentage of the refund when CBP pays. If you don’t recover, you owe nothing. The Form 4811 designee model means your ACH refund can flow directly through our account for disbursement.
The Tariff Bureau serves U.S. importers of Vietnam-origin goods remotely through our digital engagement platform. Submit your free assessment at tariffbureau.com/assessment and receive a TariffIQ™ eligibility report within minutes. For direct assistance, reach us at (404) 882-5839 or hello@tariffbureau.com, Monday through Friday, 9 AM – 6 PM Eastern.
Statutory interest continues to accrue on unrefunded IEEPA duties, so every week of delay reduces your total recovery. The earlier your CAPE Declaration is filed and validated, the more interest you collect — and with a new Section 301 duty now stacking onto Vietnamese-origin goods, getting your refund analysis underway now keeps the two matters cleanly separated.
TariffIQ™ identifies your exact CAPE phase position, your refund estimate, and your next step. Free assessment, no obligation, no recovery no fee.
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