The textile and fabric sector is one of the most trade-intensive industries in the U.S. economy. From raw cotton and synthetic fibers to woven fabrics, knit goods, and technical textiles, imported materials feed into apparel manufacturing, home furnishings, automotive interiors, medical textiles, and industrial applications. IEEPA surcharges added a punishing cost layer to an industry that already operates on tight margins and faces intense global competition.
The Supreme Court’s February 2026 ruling in Learning Resources, Inc. v. Trump struck down IEEPA tariffs, and the CIT’s March 4 order directed CBP to process refunds. For textile importers, this creates a recovery opportunity that spans raw materials, intermediate goods, and finished fabrics. The challenge is the sheer volume and complexity of textile imports.
For the full recovery framework, see the complete guide to IEEPA tariff refunds.
Which textile products qualify for IEEPA recovery
Any textile product imported from a covered country during the IEEPA period (February 2025 - February 2026) is eligible. The textile and fabric category is vast:
Fibers and yarns
Natural fibers. Cotton (raw and processed), wool, silk, linen, and specialty fibers like cashmere and alpaca. While the U.S. is a major cotton producer, processed cotton and specialty natural fibers are frequently imported.
Synthetic fibers. Polyester staple fiber, nylon filament, acrylic fiber, spandex/elastane, and polypropylene fiber. China is the world’s largest synthetic fiber producer.
Yarns. Spun yarn, filament yarn, texturized yarn, and specialty yarns in all fiber types. Yarn is a critical intermediate product that feeds into weaving, knitting, and technical textile production.
Woven fabrics
Cotton wovens. Broadcloth, poplin, twill, denim, canvas, and sheeting. These range from commodity fabrics to performance-finished materials.
Synthetic wovens. Polyester, nylon, and blended woven fabrics for apparel, home textiles, and industrial use.
Silk and specialty wovens. Silk fabrics, linen, and luxury blends from covered countries.
Knit fabrics
Jersey and interlock. Single jersey, double knit, and interlock fabrics in cotton, polyester, and blends.
Performance knits. Moisture-wicking, stretch, and technical knit fabrics for athletic and activewear applications.
Fleece and pile fabrics. Polar fleece, sherpa, and pile knits from covered origins.
Technical and industrial textiles
Nonwovens. Spunbond, meltblown, and needlepunch nonwovens used in medical, filtration, geotextile, and automotive applications.
Coated and laminated fabrics. PVC-coated, PU-coated, and membrane-laminated fabrics for outdoor, military, and industrial applications.
Filtration media. Industrial filter fabrics, automotive filter materials, and HVAC filtration textiles.
Automotive textiles. Seat fabrics, headliners, carpet, and airbag fabrics.
| Category | Typical HTS Chapters | Key Origins | Import Profile |
|---|---|---|---|
| Synthetic fibers | Ch. 54, 55 | China, India, Indonesia | Very high volume |
| Yarns | Ch. 52-55 | China, India, Pakistan | High volume |
| Woven fabrics | Ch. 52-55 | China, India, Vietnam | High volume, diverse |
| Knit fabrics | Ch. 60 | China, Vietnam, Cambodia | High volume |
| Nonwovens | Ch. 56 | China, Europe | Moderate volume |
| Technical textiles | Various | China, Japan, Korea | Moderate volume, high value |
The textile tariff landscape: separating IEEPA from the rest
Textiles have one of the most complex tariff structures of any product category. Standard MFN duty rates on textiles are among the highest in the U.S. tariff schedule — many fabrics carry rates of 7-20%, and some finished textile products face rates above 30%. IEEPA surcharges were assessed on top of these already-high rates.
For Chinese textiles, the duty stack during the IEEPA period was:
| Duty Layer | Typical Rate | Refundable? |
|---|---|---|
| MFN duty | 7-20% (varies widely) | No |
| Section 301 | 7.5-25% | No |
| IEEPA surcharge | 20-145% | Yes |
| Total | 34-390% | IEEPA only |
For textile imports from other covered countries (Vietnam, India, Cambodia, etc.), the IEEPA rate varied but was always in addition to the MFN rate. These countries don’t face Section 301 tariffs, but the IEEPA surcharge alone was significant.
Only the IEEPA surcharge is recoverable. The ES-003 report separates duties by HTS code, making it possible to isolate the IEEPA component.
Calculating recovery for textile importers
Apparel manufacturer (fabric importer)
Annual fabric import value: $12 million from multiple covered countries
- China ($5M at 145%): $7,250,000
- Vietnam ($4M at 46%): $1,840,000
- India ($3M at 26%): $780,000
- Total IEEPA recovery: $9,870,000
- Plus statutory interest: ~$600,000-$1,200,000
Home textile importer
Annual import value: $20 million in cotton and polyester fabrics from China
- IEEPA surcharge at 145%: $29,000,000
- The surcharge was nearly 150% of the product cost
Technical textile company
Annual import value: $8 million in specialty fabrics from Japan and South Korea
- Japan ($5M at 24%): $1,200,000
- South Korea ($3M at 25%): $750,000
- Total IEEPA recovery: $1,950,000
The statutory interest under 19 U.S.C. Section 1505 adds 2-4% annually on these amounts.
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Textile-specific recovery challenges
Classification complexity
Textiles have one of the most detailed classification systems in the HTS. A slight difference in fiber content, weave structure, weight, or finish can change the HTS code — and therefore the MFN duty rate and whether certain trade preferences apply. While the IEEPA surcharge was generally applied based on country of origin rather than specific classification, classification errors could affect:
- Whether an entry was correctly assessed the IEEPA surcharge
- The underlying MFN rate (which affects the total duty amount but isn’t recoverable)
- Eligibility for preferential trade programs that might have exempted certain products
Your trade compliance team should review textile classifications as part of the recovery process, looking for both overpayments (additional recovery opportunity) and misclassifications.
Country-of-origin rules for textiles
Textiles have specific country-of-origin rules that differ from general merchandise. Under the textile origin rules, the country of origin is typically where the fabric was:
- Woven or knit (for fabric), or
- Cut and sewn (for garments), or
- Formed (for nonwovens)
This means a fabric woven in China from Indonesian yarn has a Chinese origin for customs purposes. Conversely, a garment cut and sewn in Vietnam from Chinese fabric has a Vietnamese origin. These origin determinations affect which IEEPA rate applied and, therefore, the recovery amount.
If any of your entries have ambiguous origin determinations — especially for products that undergo processing in multiple countries — review the origin with your broker.
Preferential trade program interaction
Some textile imports may qualify for preferential duty treatment under programs like:
- AGOA (African Growth and Opportunity Act) for African-origin textiles
- USMCA (for North American textiles meeting origin requirements)
- GSP (for textiles from eligible developing countries)
If your textile imports qualified for preferential treatment that reduced or eliminated MFN duties, the IEEPA surcharge was still assessed separately. The recovery of the IEEPA surcharge is independent of any preferential program benefits.
Quota considerations
Textiles are subject to various quota and visa requirements. While most textile quotas were eliminated after 2005, certain monitoring and safeguard mechanisms remain. The IEEPA recovery process is separate from quota administration. Filing for a tariff refund doesn’t affect your textile quota allocation or visa requirements.
Downstream impact in textiles
The textile supply chain is long and interconnected. IEEPA surcharges on raw materials and fabrics cascaded through to:
Apparel manufacturers who incorporated imported fabrics into finished garments. If you manufacture apparel domestically using imported fabric, the IEEPA surcharge on the fabric increased your COGS. The recovery reduces that retroactively.
Home furnishing companies using imported fabrics for upholstery, bedding, curtains, and decorative textiles. Many of these products are sold through retailers with tariff surcharge pass-through arrangements.
Industrial textile users in automotive, filtration, and construction applications. If you’re a Tier 1 automotive supplier using imported fabric, your OEM customers may have contractual cost-sharing provisions.
For companies that passed IEEPA costs through to customers, review your contractual obligations before the recovery arrives.
Recovery paths for textile importers
The four recovery paths apply:
PSCs for unliquidated entries — the fastest route. Textile entries from recent months are likely still unliquidated and eligible for correction through your broker.
Protests for liquidated entries within the 180-day window. Textile importers with weekly or biweekly shipments have a continuous stream of entries requiring monitoring.
CIT litigation for entries past the window. For importers with millions in IEEPA exposure, CIT action is warranted.
Immediate capital for companies under margin pressure. Textile businesses operating on thin margins may benefit from converting claims to immediate cash. The government filing vs. immediate capital comparison helps quantify the tradeoff.
Sourcing strategy going forward
The IEEPA ruling creates an opportunity to reassess textile sourcing:
Vietnam and Southeast Asia remain competitive. Even without IEEPA tariffs, the shift to Vietnamese, Cambodian, and Bangladeshi textile production reflects structural advantages (labor costs, trade preferences, industry clusters). The IEEPA recovery doesn’t reverse this trend.
China-origin fabrics are repriced retroactively. The recovery reduces the effective cost of Chinese textiles imported during the IEEPA period. For specialty fabrics and technical textiles where Chinese suppliers have unique capabilities, this may support renewed sourcing.
India as a growing source. Indian textile imports were subject to lower IEEPA rates than Chinese imports. With IEEPA eliminated, India’s competitive position as a textile source continues to strengthen.
Near-shoring in the Americas. USMCA-origin textiles were potentially exempt from IEEPA surcharges (depending on the specific tariff structure). The case for Western Hemisphere textile sourcing now depends on USMCA origin benefits and supply chain proximity rather than tariff avoidance.
The fashion brand perspective
Fashion brands that source fabrics and finished textile products globally face specific IEEPA recovery dynamics:
Multi-season inventory. Fashion operates on seasonal collections. IEEPA-period imports correspond to specific seasons (Spring 2025, Fall 2025, Spring 2026). The recovery can be mapped to specific collections, which helps with brand-level financial analysis and season-over-season margin comparisons.
Sample and prototype imports. Fashion brands import significant volumes of fabric samples, trim samples, and garment prototypes for design development. These sample entries were subject to IEEPA surcharges and are recoverable. While individually small, the aggregate across hundreds of development samples can be meaningful.
Fabric testing and certification. Many textiles undergo testing for colorfastness, shrinkage, flammability, and other performance attributes. Testing lab imports of sample material from covered countries were also subject to IEEPA surcharges. Don’t overlook these entries.
Brand reputation and pricing. Luxury and premium brands that maintained pricing during the IEEPA period absorbed the tariff as a margin hit. The recovery restores that margin without requiring a price change — the cleanest outcome for brand equity. Budget and value brands that raised prices may face customer expectations for price reductions now that the tariff is gone.
The home textile dimension
Home textiles — bedding, bath towels, curtains, rugs, and upholstery fabrics — represent a major category of textile imports. Key considerations:
Bedding imports. Sheets, pillowcases, duvet covers, and comforters from China, India, and Pakistan were heavily affected by IEEPA surcharges. The bedding market is price-sensitive, and the tariff burden was significant relative to product cost.
Bath textiles. Towels, bath mats, and washcloths from covered countries. Turkey, China, India, and Pakistan are major suppliers.
Rug and carpet imports. Handmade and machine-made rugs from China, India, and Turkey. High-value handmade rugs can have substantial per-entry IEEPA exposure.
Window treatments. Curtains, drapes, and blinds with textile components from covered countries.
These products are often imported by retailers and e-commerce companies who may not have dedicated trade compliance staff. If you’re a home textile retailer who imports directly, don’t assume your customs broker has automatically filed for recovery — confirm and direct the process.
Fiber-level considerations
Different fiber types have different tariff profiles and different IEEPA recovery characteristics:
Cotton. The U.S. is a major cotton producer, but processed cotton fabrics (especially high-count wovens and knits) are heavily imported from China and India. The IEEPA recovery applies to the processed fabric, not to raw cotton (which is rarely imported from covered countries).
Polyester. Chinese polyester dominates the global market. Polyester fiber, yarn, and fabric from China faced the maximum 145% IEEPA rate. The recovery on polyester imports is among the largest in the textile sector.
Nylon. Nylon yarns and fabrics from China and Taiwan were subject to IEEPA surcharges. Nylon is used in activewear, outerwear, and industrial textiles.
Spandex/Elastane. China is the world’s largest spandex producer. Nearly all stretch fabrics contain Chinese spandex, even when the fabric itself is woven or knit elsewhere. If the fabric’s country of origin is the weaving/knitting country (not China), the IEEPA rate may be lower — but if spandex fiber is imported separately, those entries face the Chinese IEEPA rate.
Specialty fibers. Cashmere from China and Mongolia, silk from China, linen from China and Europe, alpaca from Peru — each has its own IEEPA rate based on country of origin.
Action plan for textile importers
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Pull the ES-003 data for all textile entries from February 2025 through February 2026.
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Separate IEEPA from MFN and Section 301. Textile MFN rates are already high — don’t confuse recoverable IEEPA surcharges with non-recoverable MFN duties.
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Verify country-of-origin determinations. Textile origin rules are specific and can affect the IEEPA rate applied.
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Monitor liquidation events. With frequent shipments, entries are liquidating continuously. Don’t miss the 180-day window.
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Review downstream contracts. Identify apparel brands, retailers, and industrial customers with tariff pass-through provisions.
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Request an Impact Assessment. The comprehensive analysis identifies every recoverable IEEPA dollar across your textile portfolio, maps deadlines, and recommends the optimal path for each entry.
The industrial textile opportunity
Beyond fashion and home textiles, industrial textiles represent a significant but often overlooked IEEPA recovery category:
Automotive textiles. Seat fabrics, headliners, carpet, trunk liners, and airbag fabrics imported from covered countries. The automotive industry imports massive volumes of technical textiles. Tier 1 automotive suppliers should evaluate their IEEPA exposure on these materials.
Geotextiles. Woven and nonwoven geotextile fabrics used in road construction, erosion control, and drainage applications. These are bulk-imported materials where the per-unit cost is low but the aggregate IEEPA exposure is significant on large civil engineering projects.
Filtration media. Industrial air and liquid filtration fabrics from covered countries. The filtration industry is heavily dependent on imported media, particularly nonwoven and microfiber fabrics from China and Japan.
Medical textiles. Surgical drapes, gowns, wound care fabrics, and implantable textiles. See also the medical devices and supplies guide for additional coverage of healthcare textile imports.
Protective textiles. Fire-resistant fabrics, ballistic textiles, and chemical-resistant materials. These high-performance textiles are often sole-sourced from specific manufacturers in covered countries, leaving importers no choice but to pay the IEEPA surcharge.
Industrial textile importers should not assume their customs broker has identified all IEEPA-eligible entries. Technical textiles may be classified under HTS chapters other than the standard textile chapters (52-63), and the IEEPA surcharge may appear on entries classified under HTS chapters for machinery, vehicles, or construction materials rather than textiles.
Textile imports are high-volume, high-complexity, and high-stakes for IEEPA recovery. The numbers add up fast. Don’t leave them unclaimed.
Request your free Impact Assessment to quantify your textile import recovery →
