Consumer Goods: A Broad IEEPA Exposure
“Consumer goods” covers a vast range of imported products — from shampoo to luggage to kitchen tools to personal care devices. This catch-all category has IEEPA exposure across dozens of HTS chapters and sourcing countries. If your business imports consumer products and you are the importer of record on your CBP entries, you almost certainly have refund opportunities to evaluate.
Key Product Categories
Personal Care and Health (Chapters 33, 34)
- 3304.99: Beauty and makeup preparations
- 3305.90: Hair preparations
- 3401.11: Soap and cleansing products
- 3808.94: Disinfectants and sanitizers
Housewares and Kitchen (Chapters 69, 70, 76)
- 6911.10: Porcelain and ceramic tableware
- 7013.37: Glass drinkware (tumblers and glasses)
- 7615.10: Aluminum table, kitchen, and household articles
- 8215.99: Cutlery and kitchen tools
Bags and Luggage (Chapter 42)
- 4202.12: Trunks and suitcases
- 4202.22: Handbags and purses
- 4202.92: Travel bags and backpacks
Personal Care Devices (Chapter 85)
- 8510.10: Electric shavers
- 8516.31: Electric hair dryers
China’s Dominance
China produces the majority of consumer goods sold in U.S. retail. At a 34% IEEPA rate, the duty burden on Chinese consumer goods was substantial. The complication — as in the toy industry — is separating IEEPA duty amounts from any applicable Section 301 tariffs on the same entries.
Opportunity for Private Label Brands
Many consumer goods companies operate private label or “white label” brands, importing products from overseas manufacturers under their own brand name. If the company is the IOR on those import entries (which is typical for direct-import private label programs), they are fully eligible for CAPE refunds.
The refund could be significant for private label brands that built their margins around a certain cost structure that included IEEPA duties — recovering those duties directly improves historical margins retroactively.
Retailers with Direct Import Programs
Large consumer goods retailers — grocery chains, drug stores, discount retailers, and specialty retail — often have direct import programs that bypass domestic distributors. In these programs, the retailer’s own purchasing entity is the IOR. These retailers are eligible claimants for the CAPE refund.
Getting Started
For consumer goods businesses, the most practical first step is using the free calculator on this site to estimate your refund based on your primary sourcing country and total import value. Once you have a sense of scale, determine whether your claim size warrants DIY filing or the engagement of a vetted recovery partner.