Amazon FBA Sellers and IEEPA Refunds
If you are an Amazon FBA seller who imported products directly from China, Vietnam, India, or other IEEPA-covered countries during 2025 through February 2026, you may be sitting on a significant refund opportunity. The key question is whether you — not Amazon, not a middleman — were the importer of record on those shipments.
Are You the Importer of Record?
Amazon FBA sellers typically fall into one of two categories:
Self-importing sellers: You arranged the freight, filed or had your freight forwarder file the customs entry under your own EIN or Social Security Number. Your name (or your LLC’s EIN) appears in Box 23 of the CBP Form 7501. You are the importer of record and are eligible to file CAPE claims.
Sellers who bought from domestic distributors or suppliers: You purchased inventory from a U.S. supplier who imported the goods. That supplier — not you — was the importer of record. You are not eligible to file CAPE claims for those goods; the refund would go to the supplier.
To determine which category applies, pull your CBP Form 7501 entries. If you used a freight forwarder to import directly from overseas, they filed entries on your behalf and your EIN is the IOR. Contact your freight forwarder for copies of all 7501s from the IEEPA period.
The De Minimis Complication
Many Amazon sellers shipped goods to the U.S. in small quantities using the Section 321 de minimis exemption (which allowed goods worth up to $800 per person per day to enter duty-free). However, CBP significantly tightened de minimis rules in 2025, particularly for goods from China. Shipments that no longer qualified for de minimis exemption — and therefore went through formal customs entry with IEEPA duties assessed — are eligible for refunds. Review your shipping records to identify which shipments paid duties.
Working with Your Freight Forwarder
Most Amazon FBA sellers who import directly use a freight forwarder or customs broker. That firm:
- Filed your customs entries under your EIN
- Paid duties on your behalf (which you reimbursed)
- Has records of all 7501 forms and duty payments
Contact your freight forwarder with a request for all entry summaries and CBP 7501 forms for the IEEPA period. Ask specifically for: entry number, entry date, HTS code, country of origin, dutiable value, and the IEEPA duty amount assessed per entry. Most freight forwarders can provide this data in an exportable format.
Common Products for Amazon Sellers
Amazon sellers across many categories have IEEPA refund exposure. The most common:
- Electronics and accessories (phone cases, cables, gadgets): China at 34%, Vietnam at 46%
- Toys and games: China at 34% — high-volume category
- Home goods and décor: China and Vietnam
- Apparel and clothing: Bangladesh, Vietnam, India
- Pet supplies: China and Vietnam
- Sports and outdoor equipment: China
Practical Steps for FBA Sellers
- Contact your freight forwarder for all 7501 forms from February 2025–February 2026 (or April 2025 for non-China sourcing)
- Confirm your EIN or SSN appears as the IOR on those forms
- Aggregate IEEPA duty amounts paid by entry
- Determine whether to self-file (manageable for 50 or fewer entries) or use a vetted recovery partner
- Ensure your ACE account is set up with your correct EIN and ACH banking information
- File as soon as your data is ready — don’t wait
For most FBA sellers with fewer than 100 entries, using our refund calculator to estimate the total, then either self-filing with the ACE portal guide or engaging a recovery partner for CSV preparation, is the most practical approach.