Apparel and Textiles: Tariff Refund Playbook

TL;DR

The US apparel industry paid an estimated $11.9 billion in 2025 tariffs. IEEPA contributed roughly 30 to 40 percent of that stack depending on country of origin.

Typical 2025 exposure: 6 to 15 percent of 2025 landed cost. Primary ports of entry: Los Angeles / Long Beach, Savannah, New York / Newark, Miami. Our licensed broker partners have filed on behalf of importers in this vertical and can handle claim preparation under 19 CFR 111.

1. The Apparel and Textiles Refund Profile

The US apparel industry paid an estimated $11.9 billion in 2025 tariffs. IEEPA contributed roughly 30 to 40 percent of that stack depending on country of origin.

Top HTS lines for this vertical:

• knit apparel (HS 61)
• woven apparel (HS 62)
• footwear (HS 64)
• textile articles (HS 63)

IOR posture: Brand importers are IOR on direct shipments. Wholesalers and distributors often are. Retailers buying FOB are not.

2. The Most Common Mistake

Relying on broker roll-up estimates instead of line-level 7501 review. First sale valuation opportunities stack on top of IEEPA refunds for 20 to 40 percent ongoing savings.

Our AI analyzer flags these kinds of issues automatically on 7501 upload. For a faster read, the IEEPA Refund Calculator returns a refund range from four inputs.

3. What You Should Do This Week

Run both the IEEPA calculator and the first sale valuation calculator. Most apparel importers have overlapping opportunities.

Concrete three-step path:

1. Pull your 2025 ACE entry history. Everything from April 2, 2025 to February 20, 2026.
2. Identify the IEEPA-dutied lines. HTS codes starting with 9903.01 indicate IEEPA exposure. Your broker can export this as a single CSV.
3. Calculate and prioritize. Claims above $250,000 get a direct broker review. Claims under that can go through the calculator and AI analyzer first to right-size the engagement.

4. Compliance Posture

Apparel and Textiles importers face the same industry-wide trap: refund mills quoting 30 percent contingency fees and promising "file today." Two reasons to walk away:

1. 19 USC 1641 makes customs business without a licensed broker a federal offense. Every filing we route goes through a licensed customs broker partner under 19 CFR 111.
2. FTC Section 5 prohibits unsubstantiated refund claims. We publish estimate ranges with the explicit "subject to CBP adjudication" caveat. Mills that promise a dollar figure on a cold-call intro are the ones the FTC pays attention to.

5. Next Steps

• Take the 60-second qualification quiz.
• Run the IEEPA Refund Calculator.
• If exposure crosses $250,000, book a 30-minute consultation.
• If you have any UFLPA, AD-CVD, or transshipment concerns, route to a customs law firm instead.

Tariff Refund Credits is a lead-generation service. Customs business is performed exclusively by our licensed customs broker partners under 19 CFR 111. Not legal or tax advice.