What does IEEPA stand for and what authority does it grant?
IEEPA stands for the International Emergency Economic Powers Act, a federal law enacted in 1977 that gives the President broad authority to regulate international commerce during a declared national emergency. Originally designed to address threats such as terrorism financing and sanctions enforcement, IEEPA has been invoked to impose a sweeping tariff on nearly all goods entering the United States.
In February 2025, an executive order citing IEEPA authority established a 10% ad valorem tariff on virtually all imported merchandise. The order declared the U.S. trade deficit a national emergency, enabling the use of IEEPA powers to impose duties outside the traditional Section 201/301/232 framework. This marked the first time IEEPA had been used as a tariff mechanism.
The legal basis is significant because IEEPA does not require an investigation by the International Trade Commission or a finding of unfair trade practices. The President can act unilaterally, which makes IEEPA tariffs faster to impose but also more likely to face legal challenges.
Which products does the IEEPA 10% tariff cover?
The IEEPA tariff applies to virtually all goods imported into the United States, regardless of country of origin. Unlike targeted measures such as Section 301 (which applies to specific products from China) or Section 232 (which covers steel and aluminum), the IEEPA tariff is a blanket rate.
Common product categories affected include consumer electronics (HTS 8471.30.01 laptops), apparel (HTS 6109.10.00 cotton t-shirts), automotive parts (HTS 8708.29.50), pharmaceuticals (HTS 3004.90.92), and agricultural goods. A $10,000 shipment of cotton t-shirts (HTS 6109.10.00) from Vietnam, which previously faced only the 16.7% MFN rate, now incurs an additional 10% under IEEPA for a total duty rate of 26.7%.
Very few categories are exempt. Goods covered by existing trade agreements may receive partial relief, but the IEEPA tariff generally stacks on top of all other applicable duty layers.
How does IEEPA stack with other tariff layers?
The IEEPA 10% tariff is additive. It stacks on top of the MFN (Most Favored Nation) duty rate, Section 301 tariffs, Section 232 tariffs, and Section 122 auto tariffs. This layering can produce substantial total duty rates.
For example, a shipment of laptop computers (HTS 8471.30.01) from China faces: MFN rate of Free + Section 301 rate of 25% + IEEPA 10% = 35.0% total duty. Zinc-coated steel (HTS 7210.49.00) from any country faces: MFN Free + Section 232 of 25% + IEEPA 10% = 35.0% total.
Importers must calculate each layer independently and sum them. There is no cap on cumulative tariff rates, which means products subject to multiple trade actions can face total duty rates exceeding 50%.