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IEEPA Tariff Refunds for Toys & Games Importers

IEEPA tariff refund guide for toy importers and game distributors, with China being the dominant sourcing country at a 34% rate.

Toys and Games: A China-Dominated Import Category

The toy and games industry is one of the most heavily concentrated on a single source country — China. Approximately 85% of toys sold in the United States are manufactured in China. At a 34% IEEPA rate, the duty burden on toy imports from China during 2025 was severe and widely reported.

The good news: IEEPA duties on Chinese toys are refundable (the IEEPA-specific layer). The complication: Section 301 tariffs on many toy categories remain in place and are not refundable.

Key HTS Codes

Chapter 95 — Toys, Games, and Sports Equipment

  • 9503.00: Tricycles, scooters, dolls, other toys (catch-all toy category)
  • 9502.10: Dolls, whether or not dressed
  • 9504.50: Video game consoles and machines
  • 9504.30: Board games
  • 9504.10–20: Video games and arcade games

The Section 301 Complication for Toys

Many toy HTS codes are subject to existing Section 301 tariffs. When reviewing your CBP 7501s for CAPE filing, you must isolate the IEEPA duty amount from the Section 301 duty amount. Both appeared on the same entry, but only the IEEPA portion is recoverable.

Fortunately, CBP’s duty assessment system assigns different collection codes to Section 301 and IEEPA duties. Your customs broker can pull these codes from your entry records and separate the amounts for you.

Video Game Consoles and Electronics Toys

Video game consoles (HTS 9504.50) are a significant category for CAPE refunds. Major gaming hardware imported from China during 2025 would have paid the 34% IEEPA rate on what are often high unit values. A shipment of gaming consoles at $300 average wholesale value generates $102 in IEEPA duty per unit — a large per-unit refund when multiplied across thousands of units.

Seasonal Inventory and Import Timing

Toy imports are highly seasonal, with the largest volumes imported in Q3 for holiday season inventory. This means the April 5–February 20 IEEPA window for non-China sourcing captured most of the 2025 holiday import season. For China-sourced toys, the February 4 start date means nearly the full 2025 import year is covered.

Who in the Supply Chain Is Eligible

In the toy industry, the eligible claimant depends on the supply chain model:

  • Brand/licensee importing directly: Eligible as IOR
  • Retailer with direct import program: Eligible as IOR
  • Retailer buying from domestic toy distributors: Not eligible; the distributor/importer is
  • Toy distributor who imported and resold: Eligible as IOR, regardless of what happened to the goods after import

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