IEEPA Tariffs
The International Emergency Economic Powers Act (IEEPA) was invoked by the Trump administration beginning in 2025 to impose broad tariffs on virtually all U.S. trading partners. These tariffs were struck down by the Supreme Court on February 20, and more than $175 Billion in importer refunds remain in dispute.
HISTORY OF THE IEEPA TARIFFS
April 2025: CBP: FAQ on IEEPA Tariffs (Generally, China, Mexico & Canada) (Official CBP guidance addressing common questions on IEEPA tariff administration, with separate sections for the general program and country-specific rules for China, Mexico, and Canada.)
April 11, 2025: CBP: CSMS Message 64724565, Exclusion of Specified Products from Reciprocal Tariffs (CBP message clarifying that certain products, including semiconductors, computers, and electronics, are excluded from the IEEPA reciprocal tariffs under a White House directive.)
April 11, 2025: POTUS: White House Memo, Clarification of Exceptions for Specified Products (EO 14257) (White House memo clarifying that electronics, semiconductors, computers, and related goods are excepted from the IEEPA reciprocal tariffs, following widespread industry concern.)
April 9, 2025: CBP: CSMS Message 64701128, Updated Guidance – China Rate Increase and Reversion of Other Country-Specific Rates (CBP implementing EO 14259, raising China's reciprocal tariff rate to 125% and reverting other country-specific rates to the 10% baseline, effective April 9, 2025.)
April 8, 2025: POTUS: Executive Order 14259, Amending the Reciprocal Tariff Rate for China (Executive order raising China's IEEPA reciprocal tariff rate to 125%, responding to China's retaliatory 34% tariffs imposed on U.S. goods.)
April 7, 2025: Federal Register: Executive Order 14257, Regulating Imports with Reciprocal Tariffs (90 FR 15625) (Official Federal Register publication of EO 14257, establishing the IEEPA reciprocal tariff framework and country-specific rates, published April 7 with a 10% baseline effective April 5.)
April 7, 2025: Federal Register: Executive Order 14256, Addressing Low-Value Shipments (De Minimis) from China (90 FR 15591) (Federal Register publication of EO 14256, eliminating the de minimis duty exemption for low-value shipments from China and directing CBP to collect applicable duties.)
April 5, 2025: CBP: CSMS Message 64680374, Guidance on Reciprocal Tariff Effective Dates (April 5 and April 9) (CBP guidance addressing the dual effective dates for IEEPA reciprocal tariffs: the 10% baseline rate took effect April 5, while higher country-specific rates took effect April 9, 2025.)
April 5, 2025: CBP: CSMS Message 64649265, Guidance on the April 5, 2025 Effective Date for Reciprocal Tariffs (CBP's initial implementation guidance for the IEEPA reciprocal tariffs, including entry filing instructions and identifying goods subject to the 10% baseline rate effective April 5, 2025.)
April 4, 2025: China MOFCOM: Announcement of 34% Retaliatory Tariffs on U.S. Goods (China's Ministry of Finance announced 34% retaliatory tariffs on all U.S.-origin imports, effective April 10, 2025, in direct response to President Trump's reciprocal tariff proclamation.)
April 2, 2025: POTUS: Executive Order 14257, Establishing Reciprocal Tariffs (President Trump invoked IEEPA to impose country-specific "reciprocal" tariffs on virtually all trading partners, citing persistent U.S. trade deficits as a national emergency.)
February 13, 2025: POTUS: White House Article, Reciprocal Trade and Tariffs (White House article outlining the administration's reciprocal trade and tariff policy, preceding the formal executive order establishing the tariff framework.)
February 13, 2025: POTUS: White House Fact Sheet on the Fair and Reciprocal Plan on Trade (Fact sheet summarizing President Trump's framework for imposing reciprocal tariff rates on countries with trade barriers, higher VATs, or other perceived trade imbalances against the United States.)
February 11, 2025: POTUS: White House Fact Sheet on Restoration of Section 232 Tariffs on Steel and Aluminum (Fact sheet announcing the restoration and expansion of Section 232 tariffs on steel and aluminum imports to 25%, as part of the administration's broader tariff and trade policy agenda.)
RECENT DEVELOPMENTS
February 20, 2026: POTUS issues two Executive Orders in response to the SCOTUS decision:
The first EO, titled ENDING CERTAIN TARIFF ACTIONS, cancels the collection of IEEPA tariffs (without impacting refund claims).
The second EO, titled Imposing a Temporary Import Surcharge to Address Fundamental International Payments Problems implements a 10% worldwide tariff (with certain exceptions) using by invoking the temporary provision of section 122 (to be effective February 24).
February 20, 2026: The U.S. Supreme Court Strikes Down President Trump's IEEPA Tariffs.
CLIENT ADVISORIES AND WHITE PAPERS
January 14, 2026: Client Alert: Prepare for SCOTUS Decision on IEEPA Tariffs
January 6, 2026: Summary: Early IEEPA Tariff Refund Litigation
January 6, 2026: White Paper: Litigation Strategy to Protect IEEPA Claims