IEEPA tariffs explained: what the reciprocal orders mean for importers

Last updated: 2026-06-02

If your landed costs jumped in 2025 and you couldn’t trace it to a Section 301 list change, the cause is probably IEEPA.

What IEEPA is

IEEPA — the International Emergency Economic Powers Act — is the statute the executive branch used in 2025 to impose tariffs by country, outside the older Section 301/232 framework. Two things make it different for importers:

• It’s country-level, not product-level. Where Section 301 targets specific HTS headings, an IEEPA surcharge can apply to broad swaths of a country’s exports.
• It introduced effective-date interactions — orders that started, paused, and resumed, sometimes within weeks. The duty owed depends on the entry date.

How it stacks

IEEPA duties are additive: they sit on top of the base MFN rate, any Section 301/232 duty, and the reciprocal baseline. For goods from China in particular, the IEEPA layer plus Section 301 plus the reciprocal baseline can more than double the effective rate versus the schedule number.

The “reciprocal” tariff

Alongside IEEPA, a reciprocal baseline tariff applies broadly across trading partners. Treat it as another additive layer in the stack — it’s part of why even goods from countries with no Section 301 exposure now carry more duty than they did in 2024.

What to do

Because IEEPA orders change on short notice, a number you calculated last month may be stale. Re-check before each purchase order with the tariff calculator, which applies the measures in force on the date you run it, and browse current duties by country to see where the IEEPA layer bites hardest. For the basics of how the layers add up, see tariff stacking explained.

Informational only — not customs advice. Classification and valuation decisions are the importer’s responsibility under 19 USC §1484. For binding rulings, file CBP Form 19; for declarations, consult a licensed customs broker.