HTS CODES

Massive supply chains — highest refund exposure

Key HTS chapters: 84 and 85

CodeProduct8541Diodes, transistors, semiconductors8542Integrated circuits / chips8534Printed circuit boards (PCBs)8535 / 8536Electrical switches, connectors8544Insulated wire, cables, harnesses8532 / 8533Capacitors, resistors8471Computers / data processing machines8473Computer parts & accessories 

 Semiconductors (HTS 8541 and 8542) were excluded from reciprocal tariffs, but passive components like capacitors and resistors are not excluded — meaning they are fully eligible for IEEPA refunds.  As of early 2025, most electronics from China were subject to a 25% Section 301 tariff plus a 20% IEEPA tariff, creating significant stacked duty exposure. 

High unit cost — large per-entry refund amounts

Key HTS chapter: 84

CodeProduct8425–8428Lifting, loading, conveying machinery8429Bulldozers, graders, excavators8430Mining/drilling machinery8456–8466Machine tools (CNC, metalworking)8477Rubber/plastics processing machinery8479General industrial machines8482Ball bearings, roller bearings8483Gearboxes, transmission shafts 

 Note: Industrial machinery was not exempt from IEEPA tariffs. High unit costs mean even a small number of entries can represent very large refund claims. 

Complex multi-layer tariff calculations

Key HTS chapters: 87 and 84

CodeProduct8407 / 8408Engines8409Engine parts8483Transmission components8708Auto parts broadly (bumpers, brakes, suspension)8706Chassis8707Bodies / cabins8714Parts for motorcycles 

 Articles subject to Section 232 duties on autos and auto parts under Proclamation 10908 are not subject to IEEPA duties — meaning if you paid Section 232 auto tariffs, those are separate and remain in effect, but IEEPA duties paid on top may be refundable. GingerControl The automotive sector faces particularly complex multi-layered tariff calculations, with companies like Toyota already in CIT litigation .

Energy + manufacturing — broad exposure

Key HTS chapters: 85 and 84

CodeProduct8501Electric motors and generators8502Generating sets8504Transformers, converters8514Industrial furnaces / heating equipment8537Control panels, switchboards8538Parts for switchgear8545 / 8546Carbon electrodes, insulators9032Automatic control instruments 

 These products were broadly subject to IEEPA tariffs with no categorical exemptions. 

High retail volume — largest number of entries

Key HTS chapters: 44, 68, 69, 72, 73, and 94

CodeProduct9401Seats / chairs9403Other furniture (desks, cabinets, shelving)9404Mattresses, bedding4418Builders' woodwork (doors, windows, flooring)4412Plywood6810Cement/concrete articles6907 / 6908Ceramic/porcelain tiles7214 / 7216Steel bars, angles (building)3918Floor coverings (vinyl, plastic) 

 Retailers importing finished consumer goods from global suppliers — including apparel, home goods, and general merchandise — are among the industries with the largest potential refund pools. The named plaintiff in the Supreme Court case, Learning Resources Inc., is a consumer goods importer from China. 

Apparel is one of the highest-exposure categories. Apparel, footwear, home goods, toys, and general merchandise importers were among the most directly impacted — Learning Resources, Inc., the named plaintiff in the Supreme Court case, is a consumer goods importer from China, illustrating how these companies bear direct impact.

ChapterCategory61Knitted or crocheted clothing62Woven clothing (non-knit)63Other made-up textile articles64Footwear65Headgear (hats, caps)  

CodeProduct6101Men's/boys' overcoats, knitted6102Women's/girls' overcoats, knitted6103Men's/boys' suits, jackets, trousers, knitted6104Women's/girls' suits, dresses, skirts, knitted6105Men's/boys' shirts, knitted6106Women's/girls' blouses, knitted6107Men's underwear, pajamas, knitted6108Women's underwear, pajamas, knitted6109T-shirts, tank tops, knitted6110Jerseys, pullovers, hoodies, sweaters6111Babies' garments, knitted6112Tracksuits, swimwear, knitted6115Pantyhose, tights, hosiery6116Gloves, mittens, knitted  

CodeProduct6201Men's/boys' overcoats, woven6202Women's/girls' overcoats, woven6203Men's suits, jackets, blazers, trousers, woven6204Women's suits, jackets, dresses, skirts, woven6205Men's/boys' shirts, woven6206Women's/girls' blouses, woven6207Men's undershirts, robes, woven6208Women's slips, robes, woven6209Babies' garments, woven6210Garments of felt or nonwovens6211Tracksuits, swimwear, woven6212Bras, corsets, girdles6214Shawls, scarves, veils6215Ties, bow ties6216Gloves, woven6217Other clothing accessories  

(High volume for retailers)

CodeProduct6301Blankets, throws6302Bed linens, table linens, towels6303Curtains, drapes6304Bedspreads, pillow covers6305Sacks and bags6306Tarpaulins, tents6307Other made-up textile articles  

(Often sourced from China/Vietnam — high tariff exposure)

CodeProduct6401Waterproof footwear6402Athletic/sports shoes, sandals6403Leather footwear6404Textile upper footwear (sneakers)6405Other footwear6406Shoe parts (soles, uppers)  

Textile and apparel articles entered free of duty under CAFTA-DR — meaning goods of Costa Rica, the Dominican Republic, El Salvador, Guatemala, Honduras, or Nicaragua — are not eligible for IEEPA refunds, as they were exempt from IEEPA tariffs in the first place.