Packaging is one of those industries where margins are measured in fractions of a cent per unit. When IEEPA surcharges landed on imported packaging materials — corrugated components, plastic containers, glass bottles, aluminum cans, labels, closures, and flexible packaging — those fractions turned into millions across high-volume operations.
The Supreme Court’s February 2026 ruling struck down IEEPA tariffs. The CIT’s March 4 order directed CBP to process refunds. For packaging importers, the recovery opportunity is substantial because the industry runs on volume. A surcharge that seems modest on a per-unit basis compounds into significant money when multiplied across millions or billions of units.
This guide covers what packaging material importers need to know. For the full recovery process, see the complete guide to IEEPA tariff refunds.
Which packaging products qualify
IEEPA surcharges applied to any packaging material imported from a covered country during the tariff period (February 2025 - February 2026). The packaging sector is broad, and the affected products span multiple material categories:
Paper and corrugated
Corrugated board and containers. Sheets, pads, and finished corrugated boxes imported from covered countries. While most corrugated packaging in the U.S. is domestically produced, imported components, specialty board, and finished boxes from China and other Asian sources were subject to IEEPA surcharges.
Folding cartons. Printed paperboard cartons for food, pharmaceutical, and consumer product packaging.
Kraft paper and linerboard. Imported kraft paper and linerboard used in domestic corrugated manufacturing.
Labels and printed matter. Paper labels, pressure-sensitive labels, and printed packaging inserts.
Plastic packaging
Bottles and containers. PET bottles, HDPE containers, PP containers, and thermoformed packaging. China is a major source of plastic bottles and containers, particularly for cosmetics, household chemicals, and personal care products.
Flexible packaging. Stand-up pouches, pillow bags, shrink film, stretch wrap, and laminated films. Many flexible packaging structures are manufactured in China and Southeast Asia.
Closures and caps. Screw caps, snap caps, dispensing closures, and child-resistant closures. These high-volume components are frequently sourced from covered countries.
Blister packs and clamshells. Thermoformed PVC, PET, and PP packaging for retail and pharmaceutical applications.
Glass containers
Glass bottles and jars. Food-grade, beverage, pharmaceutical, and cosmetic glass containers. China is the world’s largest glass container producer, and imports of Chinese glass packaging were hit with the highest IEEPA rates.
Glass vials and ampoules. Pharmaceutical glass containers, often imported from China and India.
Metal packaging
Aluminum cans and ends. Beverage cans, food cans, and aerosol containers. See also the steel and metal imports guide for additional context on metal tariff layers.
Tinplate containers. Decorative tins, food cans, and specialty metal packaging.
Aluminum foil packaging. Blister foil, container foil, and laminated foil structures.
Other packaging materials
Wooden crates and pallets. Shipping crates, pallets, and dunnage. See the lumber and wood products guide for more detail.
Cushioning and fill. Foam packaging, air pillows, molded pulp, and loose fill materials.
Strapping and banding. Steel and plastic strapping, banding, and securing materials.
| Packaging Category | Typical HTS | Key Origins | Volume Profile |
|---|---|---|---|
| Corrugated | Ch. 48 | China | High volume |
| Plastic containers | Ch. 39 (3923) | China, Vietnam | Very high volume |
| Flexible packaging | Ch. 39 (3920, 3921) | China, India | High volume |
| Closures | Ch. 39, 83 | China, Taiwan | Extreme volume |
| Glass containers | Ch. 70 (7010) | China, Mexico | Moderate-high volume |
| Aluminum cans | Ch. 76 (7612) | China | High volume |
The volume multiplier effect
Packaging is unique among import categories because the per-unit value is extremely low but the unit counts are enormous. Consider:
A beverage company importing 100 million glass bottles from China at $0.15 per bottle:
- Total import value: $15,000,000
- IEEPA surcharge at 145%: $21,750,000
- The surcharge nearly equals the total value of goods
A food company importing 50 million plastic containers from China at $0.08 per unit:
- Total import value: $4,000,000
- IEEPA surcharge at 145%: $5,800,000
A consumer products company importing 200 million closures from China at $0.03 per unit:
- Total import value: $6,000,000
- IEEPA surcharge at 145%: $8,700,000
The numbers compound fast. Even importers who don’t think of themselves as “big importers” can have substantial IEEPA exposure on packaging alone.
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Industry-specific considerations
Packaging as an indirect import
Many companies don’t import packaging directly. They buy packaging from domestic converters who import the raw materials or components. In these cases:
If the domestic converter imported the materials, the recovery right belongs to the converter (as the importer of record), not to you as the customer. However, if the converter passed IEEPA tariff costs through to you in pricing, you may have a contractual basis for a share of the recovery.
If you import your own packaging directly, you are the importer of record and the recovery right is yours. File through your customs broker.
If you use a third-party logistics provider or trading company as the IOR, the recovery right may belong to them. Clarify the IOR designation on your entries.
Contract packaging implications
Companies that use contract packagers (co-packers) face a similar question. If the co-packer imports the packaging materials, the tariff recovery right is theirs. Review your co-packing agreement for any provisions about tariff costs, cost pass-through, or extraordinary receipts.
Sustainability and material shifts
Many packaging companies shifted to alternative materials or alternative sourcing during the IEEPA period to reduce tariff exposure. Examples:
- Switching from Chinese glass to Mexican glass bottles
- Shifting to domestic plastic packaging suppliers
- Converting from imported rigid packaging to domestic flexible packaging
The IEEPA recovery changes the retroactive economics of these decisions but doesn’t necessarily justify reversing them. The sustainability, quality, and supply security reasons for material or sourcing shifts may remain valid. The procurement guide covers how to evaluate these decisions in light of the recovery.
Multi-entry consolidation
Packaging imports often arrive as part of larger consolidated shipments. A single container might include packaging materials, product components, and finished goods, all under one entry summary. The IEEPA surcharge applies to each line item based on its HTS classification. Make sure the recovery filing captures every IEEPA-eligible line item within consolidated entries — not just the main product.
Recovery paths for packaging importers
The four recovery paths apply:
PSCs for unliquidated entries — file immediately. Packaging importers with continuous monthly shipments likely have many recent entries still unliquidated. These recover fastest.
Protests for liquidated entries within the 180-day window. With high shipment frequency, packaging importers may have entries liquidating every week. Set up a systematic tracking process to catch every deadline.
CIT litigation for entries past the window. Evaluate on a cost-benefit basis. For high-volume packaging importers, even entries with moderate per-entry IEEPA amounts may justify CIT action when aggregated.
Immediate capital through claim assignment. Packaging companies operating on thin margins may find immediate cash more valuable than waiting 18-36 months for government processing. The treasury cash flow analysis can help model the decision.
Downstream customer exposure
Packaging costs are embedded in virtually every consumer product. If you’re a packaging supplier who raised prices during the IEEPA period citing tariff costs, your customers may assert claims to a share of the recovery.
Key risk areas:
- Brand owners who contracted for packaging at tariff-inflated prices may request retroactive adjustments
- Retailer private label programs with cost-plus pricing structures
- Food and beverage companies with long-term supply agreements that include raw material cost-sharing provisions
Review your customer agreements before the recovery funds arrive. The in-house counsel guide covers the legal framework for managing these claims.
Data challenges in packaging recovery
Packaging importers face some unique data challenges:
High entry volume. A large packaging importer might have thousands of entries from the IEEPA period. The operations manager’s guide covers the workflow for managing high-volume recovery data.
Small per-entry amounts. Some entries may have relatively small IEEPA surcharges (hundreds or low thousands of dollars). While individually modest, these add up across thousands of entries. Don’t skip small entries — they’re recoverable too.
Mixed entries. Entries that combine packaging with other products require line-item analysis to isolate the IEEPA surcharge on the packaging components specifically.
Broker fragmentation. Companies importing packaging through multiple ports may use different brokers, creating data silos. Coordinate across all brokers to ensure complete capture.
The ES-003 report from ACE provides the authoritative entry-level data. Request it from every broker who handled your IEEPA-period packaging imports.
The brand owner perspective
Many brand owners don’t import packaging directly — their co-packers, contract manufacturers, or packaging converters do. But brand owners are often the economic parties who bore the tariff cost through higher packaging prices. Here’s how brand owners should approach the IEEPA recovery:
Review co-packer agreements. If your co-packer imported packaging materials and passed the IEEPA tariff cost through to you, the recovery belongs to the co-packer (as the IOR). However, your co-packing agreement may include provisions that entitle you to a share of any cost reductions, including tariff refunds. Flag this for your legal team.
Direct packaging procurement. If your company imports packaging directly (which is common for large CPG companies with dedicated packaging procurement), you are the IOR and the recovery is yours. File through your customs broker.
Packaging specification changes. Some brand owners changed packaging specifications during the IEEPA period to accommodate alternative-origin materials. If you switched from a Chinese glass bottle to a domestic PET bottle, or from a Chinese flexible pouch to a domestic rigid container, the IEEPA recovery changes the retroactive economics of those decisions. The capital can fund a reassessment of packaging specifications.
Food and beverage packaging specifics
Food and beverage companies consume enormous volumes of imported packaging:
Beverage cans and bottles. The beverage industry imports billions of cans, bottles, and closures. Even a small IEEPA surcharge per unit creates a massive aggregate claim. A major beverage company importing one billion closures at $0.02 per closure from China faces $29 million in IEEPA surcharges at 145%.
Aseptic packaging. Tetra Pak and similar aseptic packaging materials may include imported components (laminated structures, closures) from covered countries.
Fresh produce packaging. Clamshells, bags, and trays for fresh produce are heavily sourced from China. The produce industry operates on extremely tight margins, making the IEEPA recovery particularly impactful.
The e-commerce and fulfillment dimension
E-commerce growth has driven increased demand for shipping packaging — corrugated boxes, mailers, protective packaging, and void fill. If your company imports shipping packaging from covered countries:
Amazon and marketplace sellers. If you’re a marketplace seller who imports packaging for your fulfillment operation, you may have IEEPA claims. The amounts may be smaller than industrial importers, but they’re still recoverable.
3PL and fulfillment companies. Third-party logistics providers who import packaging materials for their clients may hold the IOR status and therefore the recovery right. Alternatively, if the 3PL purchases packaging on behalf of clients and passes the cost through, the recovery question depends on the contractual arrangement.
Subscription box companies. The subscription box market imports significant volumes of custom packaging — printed boxes, inserts, and branded materials — from China. The IEEPA recovery on these imports can be substantial relative to the company’s overall cost structure.
Action plan for packaging importers
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Inventory your packaging import exposure. Include both direct imports and imports by affiliated companies or co-packers where you may have a contractual interest.
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Pull ES-003 data from all brokers. Ensure every entry from every port is captured.
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Map deadlines. With high entry frequency, liquidation events and protest deadlines are occurring continuously. Build automated tracking.
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Evaluate per-entry economics. For very small entries, batch them together for filing efficiency. Don’t skip them — the aggregate matters.
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Review customer contracts. Identify any tariff pass-through or cost-sharing provisions.
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Request an Impact Assessment. It provides the comprehensive entry-level analysis across all your packaging imports, with IEEPA duties isolated, deadlines mapped, and recovery paths assigned.
Sustainability packaging and the IEEPA recovery
The packaging industry is in the middle of a sustainability transformation. Many companies are investing in biodegradable, compostable, or recyclable packaging materials — some of which are imported from covered countries:
Compostable packaging materials. PLA (polylactic acid) films, molded fiber products, and bio-based packaging from China and other Asian producers carried IEEPA surcharges. These products are often more expensive than conventional packaging, making the tariff burden disproportionately impactful.
Recycled content packaging. Packaging made from post-consumer recycled materials imported from covered countries was subject to IEEPA surcharges. The surcharge made recycled-content imports less competitive versus domestic virgin materials, undermining sustainability goals. The recovery restores the economic case for imported recycled-content packaging.
Paper-based alternatives to plastic. The shift from plastic to paper-based packaging drove increased imports of specialty paperboard and molded pulp products from covered countries. These entries carry IEEPA surcharges and are recoverable.
The recovery capital can fund further sustainability investments in packaging — new materials, supply chain optimization, and certification programs — creating a positive cycle where trade policy recovery supports environmental goals.
Industrial packaging and shipping materials
Beyond consumer-facing packaging, industrial packaging materials represent a large import category:
Stretch wrap and shrink film. Used in pallet wrapping, bundling, and industrial packaging applications. High-volume, low-value-per-unit category with significant aggregate IEEPA exposure.
Strapping and banding. Steel and polyester strapping for securing palletized loads. Steel strapping may also carry Section 232 tariffs — separate IEEPA from Section 232 on these entries.
Dunnage and void fill. Air pillows, foam inserts, and paper-based void fill materials imported from covered countries. Often overlooked in recovery analyses because they’re considered incidental to the main shipment.
Pallets and crates. Wooden pallets and shipping crates from covered countries. See the lumber guide for wood packaging specifics.
IBC (intermediate bulk containers). Reusable plastic and composite IBCs from covered countries. These are relatively high-value packaging items where the per-unit IEEPA surcharge is significant.
Label and printed packaging
The label and printed packaging segment deserves special mention because it’s often classified separately from the container it decorates:
Pressure-sensitive labels. Self-adhesive labels on release liner, imported from China and other Asian producers. These are extremely high-volume imports — billions of labels per year for food, beverage, personal care, and pharmaceutical applications.
Shrink sleeves. PVC, PET, and OPS shrink sleeves for bottles and containers. The decorative sleeve is a separate import from the container itself, with its own entry and its own IEEPA surcharge.
Printed cartons and inserts. Folding cartons, package inserts, and printed paperboard components from covered countries.
These items are often low-value per unit but imported in enormous quantities. The cumulative IEEPA exposure across all label and printed packaging entries can be surprisingly large.
Packaging operates on volume and margins. The IEEPA recovery is volume money — it compounds across every entry, every shipment, every container load. Don’t underestimate it because the per-unit numbers seem small.
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