Not every industry was hit equally by IEEPA tariffs. While the tariffs applied broadly across product categories and countries, certain sectors bore a disproportionate share of the $166 billion in duties collected between February 2025 and February 2026. Those same sectors now stand to recover the most — but only if they file.
The Supreme Court’s ruling struck down IEEPA tariffs across the board, meaning every dollar collected is refundable regardless of industry. But the size of the opportunity varies dramatically by sector. A consumer electronics company that imported $100 million from China faces a very different refund calculus than a domestic manufacturer that sourced $2 million in components from Canada.
Below are the five industries with the largest aggregate IEEPA tariff exposure, ranked by estimated total duties paid. For each, we break down why the exposure is so high, what the average per-company refund looks like, and the sector-specific challenges in recovering it.
1. Electronics and Technology
Estimated sector IEEPA tariff exposure: $35–45 billion
Electronics was ground zero for IEEPA tariffs. China is the world’s largest exporter of consumer electronics, components, and computer hardware, and the 20% IEEPA surcharge on top of existing Section 301 tariffs pushed effective duty rates on many electronics products to 45–70% of entered value.
Why the exposure is so high
The electronics supply chain is deeply tied to China. Despite years of diversification efforts, China still accounted for roughly 65–70% of U.S. electronics imports during the IEEPA tariff period. Products affected include:
- Smartphones and tablets — assembled primarily in China
- Laptops and computers — both finished products and components
- Semiconductors and integrated circuits — though some exclusions applied
- Consumer electronics — TVs, audio equipment, smart home devices
- Networking equipment — routers, switches, servers
- Electronic components — PCBs, connectors, capacitors, displays
The combination of high import volume and high duty rates creates enormous per-company exposure. A mid-size electronics distributor importing $50 million annually from China at a 20% IEEPA surcharge has approximately $10 million in refundable tariffs — and that’s just the China surcharge, not counting reciprocal tariffs on components sourced from other Asian countries.
Average per-company refund potential
| Company Size (Annual Electronics Imports) | Estimated IEEPA Refund |
|---|---|
| Small ($5M–$20M) | $1M–$4M |
| Mid-size ($20M–$100M) | $4M–$20M |
| Large ($100M–$500M) | $20M–$100M |
| Enterprise ($500M+) | $100M+ |
Key HTS codes
Electronics importers should look for IEEPA duties on HTS codes in Chapters 84 (machinery and computers), 85 (electrical equipment), and 90 (optical and measuring instruments). The IEEPA surcharge codes under 9903.01 apply to virtually all products in these chapters when sourced from China.
Recovery challenges
Electronics portfolios tend to have high entry counts — thousands or even tens of thousands of entries over the 12-month period. This creates data management complexity for CAPE filing and increases processing time. Companies in this sector should start data preparation early to ensure first-wave CAPE filing.
Additionally, electronics importers often have entries with layered duties: MFN + Section 301 + IEEPA. Correctly separating the IEEPA component from the Section 301 component is critical — only the IEEPA surcharge is refundable. The refund amount calculator helps with this separation.
2. Retail and Consumer Goods
Estimated sector IEEPA tariff exposure: $30–40 billion
Retail is the second-hardest-hit sector by total exposure, driven by massive import volumes across virtually every consumer product category. From furniture to kitchenware to toys to sporting goods, the retail supply chain sources heavily from China and the reciprocal tariff countries.
Why the exposure is so high
Retail importers bring in enormous volumes of relatively low-value goods. The per-unit tariff might seem small, but multiplied across millions of units, the aggregate exposure is staggering. A single big-box retailer might have $500 million+ in IEEPA tariff exposure from a year of importing.
Product categories with the highest retail exposure:
- Furniture and home furnishings — heavily sourced from China and Vietnam
- Toys and games — China dominates manufacturing
- Kitchenware and housewares — broad country sourcing hit by reciprocal tariffs
- Sporting goods and outdoor equipment — mixed China and Southeast Asian sourcing
- Pet products — significant China sourcing
- Seasonal and holiday merchandise — imported in bulk, high volume
The reciprocal tariffs (April 2025 onward) hit retail particularly hard because they expanded beyond China to include Vietnam, India, Indonesia, and other countries that retailers had diversified into specifically to avoid Section 301 tariffs. IEEPA effectively closed the escape valve.
Average per-company refund potential
| Retailer Size | Estimated IEEPA Refund |
|---|---|
| Specialty retailer ($10M–$50M imports) | $2M–$12M |
| Mid-size chain ($50M–$200M imports) | $12M–$50M |
| Large retailer ($200M–$1B imports) | $50M–$250M |
| Major national chain ($1B+ imports) | $250M+ |
Recovery challenges
Retail portfolios are characterized by extremely high entry volumes and product diversity. A mid-size retailer might have 10,000–50,000 entries across hundreds of product categories. Data management is the primary challenge — pulling, validating, and formatting this volume of data for CAPE filing is a significant undertaking.
Retailers who passed tariff costs to consumers face an additional consideration: the refund goes to the IOR (the retailer), not the consumer. How retailers handle this windfall — reinvest, reduce prices, return to shareholders — is a business decision, but it’s worth thinking through before the money arrives.
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3. Automotive and Transportation
Estimated sector IEEPA tariff exposure: $20–30 billion
The automotive sector’s exposure comes from two directions: finished vehicle imports (primarily from Canada and Mexico) and component/parts imports (from China, Mexico, Japan, and other countries). The 25% IEEPA tariffs on Canada and Mexico were particularly devastating for an industry built on North American supply chain integration.
Why the exposure is so high
Under NAFTA and later USMCA, the North American auto industry integrated deeply across the U.S., Canada, and Mexico. Parts cross borders multiple times during assembly. The 25% IEEPA tariff on Canadian and Mexican imports disrupted this entire system and created enormous duty exposure.
Key automotive categories affected:
- Finished vehicles imported from Canada and Mexico (25% IEEPA tariff)
- Auto parts and components — engines, transmissions, body panels, electrical systems
- Tires and rubber products — sourced from multiple affected countries
- EV batteries and components — significant China and reciprocal-country sourcing
- Aftermarket parts — broad country sourcing hit by reciprocal tariffs
- Heavy truck and commercial vehicle components
A single large automaker importing $2 billion in parts from Canada and Mexico during the IEEPA period faced approximately $500 million in IEEPA tariff exposure on those imports alone. Adding China-sourced components and reciprocal tariff countries pushes the number even higher.
Average per-company refund potential
| Company Type | Estimated IEEPA Refund |
|---|---|
| Auto parts distributor ($20M–$100M imports) | $5M–$25M |
| Tier 1 supplier ($100M–$500M imports) | $25M–$125M |
| OEM / assembler ($500M–$2B imports) | $125M–$500M |
| Major automaker ($2B+ imports) | $500M+ |
Key HTS codes
Automotive importers should focus on HTS Chapter 87 (vehicles and parts) and Chapter 40 (rubber products), plus relevant components in Chapters 84 (machinery), 85 (electrical), and 73 (steel articles). For Canada/Mexico imports, the IEEPA surcharge codes under 9903.01 apply broadly.
Recovery challenges
Automotive has unique complexity due to USMCA rules of origin. Some entries may have qualified for preferential treatment under USMCA that was then overridden by IEEPA tariffs. Unwinding these interactions requires careful analysis. Large OEMs also face the challenge of entries filed by multiple entities (subsidiaries, JV partners, contract manufacturers) that may each need to file separately.
The four recovery paths are all relevant for automotive — PSCs for recent unliquidated entries, protests for liquidated entries, CAPE for the bulk, and immediate capital for companies facing cash flow pressure from supply chain disruptions.
4. Industrial Manufacturing and Machinery
Estimated sector IEEPA tariff exposure: $15–25 billion
Industrial manufacturers import raw materials, components, machinery, and equipment from around the world. The combination of China-specific tariffs and broad reciprocal tariffs hit this sector from every angle — whether they were importing Chinese steel components, German machinery, or Japanese precision instruments.
Why the exposure is so high
Manufacturing supply chains are global and complex. A single finished product might contain components from 10+ countries, each subject to different IEEPA tariff rates. The sector’s exposure comes from:
- Industrial machinery and equipment — CNC machines, presses, molds from China, Germany, Japan
- Raw materials — metals, chemicals, plastics from multiple affected countries
- Components and sub-assemblies — motors, sensors, valves from China and Asia
- Tools and dies — significant China sourcing
- Industrial electronics — PLCs, controllers, industrial computers
The reciprocal tariffs were particularly impactful for manufacturers who had diversified away from China to Europe or Japan — countries that were also hit with 10–20% reciprocal rates. There was essentially no tariff-free sourcing option.
Average per-company refund potential
| Company Size | Estimated IEEPA Refund |
|---|---|
| Small manufacturer ($5M–$25M imports) | $1M–$6M |
| Mid-size manufacturer ($25M–$100M imports) | $6M–$25M |
| Large manufacturer ($100M–$500M imports) | $25M–$100M |
| Industrial conglomerate ($500M+ imports) | $100M+ |
Recovery challenges
Industrial manufacturers often have complex entry classifications with mixed duty types. A single entry might include components classified under different HTS codes with different base rates, Section 232 applicability (for steel/aluminum), Section 301 rates, and IEEPA surcharges. Separating the IEEPA-specific component requires line-by-line analysis.
Many manufacturers also use bonded warehouses and foreign trade zones (FTZs), which create additional complexity in determining duty liability and entry timing. If goods entered an FTZ before the IEEPA period and were withdrawn during it, the duty implications may differ from direct imports.
5. Apparel, Footwear, and Textiles
Estimated sector IEEPA tariff exposure: $12–18 billion
Apparel and textiles have always been heavily imported, with China, Vietnam, Bangladesh, India, and other developing countries dominating production. IEEPA tariffs — particularly the reciprocal tariffs — hit this sector hard because it relies almost entirely on foreign manufacturing.
Why the exposure is so high
The apparel industry had already been shifting production from China to Vietnam, Bangladesh, Cambodia, and other lower-cost countries to avoid Section 301 tariffs. The reciprocal tariffs imposed under IEEPA authority targeted these exact countries, eliminating the cost advantage of diversification and creating new tariff exposure where none previously existed.
Key categories affected:
- Clothing and garments — sourced from dozens of affected countries
- Footwear — China, Vietnam, Indonesia dominate manufacturing
- Textiles and fabrics — China, India, Pakistan, Bangladesh
- Accessories — bags, belts, hats from China and Southeast Asia
- Home textiles — bedding, towels, curtains from China, India, Pakistan
For apparel importers, the reciprocal tariff rates were devastating: Vietnam at 46%, Bangladesh at 37%, Cambodia at 49%, India at 26%. Even the reduced rates after the 90-day pause (10% universal) represented significant new cost on goods that previously entered duty-free or at low MFN rates.
Average per-company refund potential
| Company Type | Estimated IEEPA Refund |
|---|---|
| Specialty brand ($10M–$50M imports) | $2M–$12M |
| Mid-size apparel company ($50M–$200M imports) | $12M–$40M |
| Large fashion retailer ($200M–$1B imports) | $40M–$150M |
| Major apparel conglomerate ($1B+ imports) | $150M+ |
Key HTS codes
Apparel importers should focus on HTS Chapters 61–63 (clothing and textiles) and Chapter 64 (footwear). The IEEPA surcharge codes under 9903.02 apply to imports from reciprocal tariff countries, while 9903.01 covers China-sourced apparel and textiles.
Recovery challenges
Apparel has extremely high entry volumes — a major retailer might file 50,000+ entries in a year — and seasonal importing patterns that concentrate entries in specific months. The data volume makes CAPE preparation time-consuming, and the seasonal concentration means many entries may liquidate around the same time, creating a cluster of 180-day protest deadlines.
Many apparel companies also have thin margins, making the tariff refund particularly impactful for financial performance. These companies may benefit significantly from immediate capital to restore working capital for the next buying season rather than waiting 18–36 months for CAPE processing.
Exposure Ranking Summary
| Rank | Industry | Estimated IEEPA Exposure | Avg. Mid-Size Company Refund | Primary Tariff Source |
|---|---|---|---|---|
| 1 | Electronics & Technology | $35–45B | $4M–$20M | China 20% + reciprocal |
| 2 | Retail & Consumer Goods | $30–40B | $12M–$50M | China + reciprocal |
| 3 | Automotive & Transportation | $20–30B | $25M–$125M | Canada/Mexico 25% + China |
| 4 | Industrial Manufacturing | $15–25B | $6M–$25M | Reciprocal + China |
| 5 | Apparel & Textiles | $12–18B | $12M–$40M | Reciprocal + China |
These five sectors account for roughly $112–158 billion of the total $166 billion in IEEPA tariff exposure — approximately 70–95% of all refundable duties.
Honorable Mentions: Other High-Exposure Sectors
While the top five account for the bulk of IEEPA tariff exposure, several other sectors have significant refund potential.
Pharmaceuticals and Medical Devices
The medical device and pharmaceutical ingredients supply chain relies heavily on China and India. Active pharmaceutical ingredients (APIs), medical equipment, and lab supplies all faced IEEPA surcharges. Companies in this sector should check entries under HTS Chapters 29–30 (pharmaceutical products) and 90 (medical instruments). Estimated sector exposure: $5–10 billion.
Agriculture and Food Products
Agricultural imports from Canada and Mexico — two of the largest U.S. agricultural trading partners — were hit with 25% IEEPA tariffs. Fresh produce, processed foods, beverages, and agricultural commodities from reciprocal tariff countries were also affected. The perishable nature of many agricultural products meant companies couldn’t delay imports to avoid the tariffs. Estimated sector exposure: $8–12 billion.
Construction and Building Materials
Lumber from Canada, steel products already under Section 232 but now with additional IEEPA surcharges, concrete additives from China, and building hardware from multiple countries all faced IEEPA duties. The construction sector’s fragmented importing structure (many small to mid-size importers) means individual claims may be smaller, but the aggregate is substantial. Estimated sector exposure: $5–8 billion.
Chemicals and Plastics
Specialty chemicals, plastic resins, industrial gases, and chemical intermediates sourced from China and other affected countries faced IEEPA surcharges that significantly increased input costs for manufacturers. Companies in this sector often have complex supply chains with multiple entry points, making data preparation more involved. Estimated sector exposure: $4–7 billion.
What Your Industry Should Do Next
Regardless of which industry you’re in, the next steps are the same:
- Quantify your exposure — Pull your ES-003 report and identify all IEEPA duties. The refund amount calculator can help.
- Categorize your entries — Separate unliquidated entries (PSC-eligible), protest-window entries, and older liquidated entries. Each needs a different recovery path.
- File PSCs immediately for unliquidated entries — this is the fastest path to recovery.
- Protect liquidated entries — File protests before the 180-day window closes.
- Prepare for CAPE — Have your data validated and ready for day-one submission.
- Evaluate immediate capital — If cash flow matters more than maximum recovery, claim assignment delivers payment in 14–21 days.
The cost of waiting applies equally across all industries. Your competitors in every sector listed above are already filing. The CAPE queue is forming. And protest deadlines are expiring on a rolling basis.
Our Impact Assessment analyzes your specific portfolio — regardless of industry — and gives you a precise refund estimate, entry-by-entry status analysis, and a tailored recovery strategy.
