IEEPA Tariffs Start Date: When Did They Begin and What's the Refund Window?

Key IEEPA Start Dates

Not all IEEPA tariffs began on the same date. Understanding when tariffs became effective for your specific country of origin is critical to identifying which of your entries fall within the refund window.

February 4, 2025 — Canada, Mexico, and China

The IEEPA tariff program began on February 4, 2025, with executive orders targeting Canada, Mexico, and China. These orders were announced in late January 2025 and took effect at midnight on February 4.

• Canada: 25% IEEPA tariff (with USMCA carve-outs for qualifying goods)
• Mexico: 25% IEEPA tariff (with USMCA carve-outs for qualifying goods)
• China: Initial IEEPA rate (later escalated; total IEEPA-specific duty layer varies)

Any goods entering U.S. customs on or after February 4, 2025 from these three countries were potentially subject to IEEPA duties. Goods that were already in transit on February 4 but cleared customs after that date were included; goods that cleared before February 4 were not.

April 5, 2025 — All Other Countries (“Liberation Day”)

The broader “reciprocal” tariff schedule covering the rest of the world took effect on April 5, 2025. This single order covered more than 80 trading partners with country-specific rates ranging from 10% to 46%.

All entries from these countries on or after April 5, 2025 were subject to the applicable IEEPA reciprocal rate.

February 20, 2026 — End of the IEEPA Duty Period

The IEEPA tariff regime ended effectively on February 20, 2026, when the Supreme Court issued its ruling in V.O.S. Selections Inc. v. United States. Duties assessed and collected on entries cleared through February 20, 2026 are within the refund window.

CBP stopped assessing IEEPA reciprocal duties as of the ruling date. (The administration quickly pivoted to Section 122 duties, which began February 24, 2026 — those are a separate, non-refundable matter.)

The Refund Window by Country

Country	Refund Window Start	Refund Window End
Canada	Feb 4, 2025	Feb 20, 2026
China	Feb 4, 2025	Feb 20, 2026
Mexico	Feb 4, 2025	Feb 20, 2026
Vietnam	Apr 5, 2025	Feb 20, 2026
India	Apr 5, 2025	Feb 20, 2026
EU countries	Apr 5, 2025	Feb 20, 2026
Japan	Apr 5, 2025	Feb 20, 2026
South Korea	Apr 5, 2025	Feb 20, 2026
Thailand	Apr 5, 2025	Feb 20, 2026
All others	Apr 5, 2025	Feb 20, 2026

What “Entry Date” Means for CAPE Purposes

For CAPE refund filing, the relevant date is the date the entry was filed with CBP (the consumption entry date shown on CBP Form 7501), not the date goods were shipped, loaded, or arrived at port. This is an important distinction:

• If goods were shipped from Vietnam on March 15, 2025 and arrived at the Port of Los Angeles on April 2, 2025, but didn’t clear customs (entry filed) until April 7, 2025, the entry date is April 7 — within the IEEPA window.
• If the same shipment cleared customs on April 4, 2025, before the April 5 effective date, the entry is outside the window.

Always use the consumption entry date from your CBP 7501, not any other date in your logistics records.

What About Goods in Transit on February 4, 2025?

Goods physically in transit (on a ship, aircraft, or otherwise in movement) when the IEEPA orders took effect were generally subject to the tariff if they cleared customs after the effective date. CBP typically does not provide “in-transit” exemptions for tariff orders of this type.

This matters primarily for imports from Canada, Mexico, and China, where the February 4 start date was a sudden change from existing duty-free treatment for USMCA goods or pre-existing tariff rates for Chinese goods.

Gray Zone: Late January / Early February 2025 China Shipments

For imports from China, the tariff situation in early 2025 was particularly volatile. The administration announced, then briefly paused, then reimposed several IEEPA actions. Importers with Chinese goods entering the U.S. in late January and early February 2025 should carefully review their entry summaries to determine exactly which duty assessments were applied and when.

For the CAPE refund process, what matters is the actual duty collected on each 7501 — if IEEPA duties appear on the form, they are presumptively refundable for entries within the covered period.

Practical Steps to Determine Your Window

1. Identify all countries of origin from which you imported during 2025 through February 20, 2026
2. Match each country to its IEEPA start date (February 4 for Canada/China/Mexico; April 5 for all others)
3. Pull all entry summaries (CBP Form 7501) for that period
4. Check the consumption entry date on each entry against the applicable start date
5. Confirm IEEPA duties were collected — look for the IEEPA-specific duty line on the form
6. Calculate total IEEPA duties paid across eligible entries — that’s your refund basis

Our free calculator provides a quick estimate. For actual filing, you’ll need the per-entry detail pulled from ACE or provided by your customs broker.