Which HTS Codes Carry IEEPA Duties (and How to Check Yours)
Chen Cui Co-Founder of GingerControl What changed: Reviewed CAPE phase dates, appeal and totals against B1 source correction: existing dated court/CBP references retained; $136.6B accepted and $126B certified distinguished. Replaced inaccessible CourtListener opinion with official CIT Slip Op.26-123 (October8,2026); $166B universe is historical March2026 CBP estimate.
IEEPA duties rode on Chapter 99 codes in two ranges: 9903.01.xx for the trafficking tariffs (the Canada, Mexico, and China fentanyl measures, plus later additions) and 9903.02.xx for the country-specific reciprocal tariffs. If an entry line carries one of those 9903.01 or 9903.02 secondary codes, it carried IEEPA duty. A base Chapters 1-98 code never carries IEEPA duty by itself. IEEPA duties are no longer collected: after the Supreme Court's February 20, 2026 ruling, CBP stopped collecting them for goods entered on or after February 24, 2026, and those codes are inactive in ACE. What applies now is the Section 301 forced-labor duty of 10% or 12.5% on products of 60 economies, in force since July 24, 2026 (a 10% Section 122 surcharge covered February 24 to July 23, 2026), alongside Section 232 and the China Section 301 lists. Today the 9903.01 and 9903.02 codes matter for refunds.
In this post
- How do I check whether my own HTS lines were hit by IEEPA?
- TL;DR
- Why IEEPA duties live in Chapter 99, not on your base code
- The two IEEPA code families: 9903.01 vs 9903.02
- Chapter 99 codes that look like IEEPA but are not
- How do you check whether your HTS lines carried IEEPA duty?
- Where GingerControl fits in the code-reading step
- Frequently asked questions
- Reading your IEEPA-bearing lines before you build a refund claim
- References
- Related Articles
How do I check whether my own HTS lines were hit by IEEPA?
Pull the entry summary line detail (the ES-003 report) from ACE and scan the Chapter 99 column for any 9903.01.xx or 9903.02.xx code. Those lines, and only those, are the ones that paid IEEPA duty and are in scope for the 2026 refund process (CAPE). Section 232 (9903.80/81/85), Section 301 (9903.88), and Section 122 (9903.03) codes are not IEEPA and not part of that refund.
TL;DR
IEEPA duties never sat on your base HTS code. They were collected through Chapter 99 secondary codes: 9903.01.xx for the trafficking tariffs (Canada/Northern Border, Mexico/Southern Border, China/PRC synthetic opioids, plus later Venezuela-nexus and Brazil/India measures) and 9903.02.xx for the country-specific reciprocal "trade deficit" tariffs covering 60-plus countries. After the Supreme Court struck down IEEPA tariffs on February 20, 2026 in Learning Resources, Inc. v. Trump (6-3), CBP stopped collecting them for goods entered on or after February 24, 2026 and, under a Court of International Trade order, is refunding them through CAPE: of roughly $166 billion paid across about 53 million entries, about $126 billion with interest had been certified and sent to Treasury by October 2, 2026. GingerControl's IEEPA refund service sorts an importer's entries by refund route and deadline and prepares the refund file, and our licensed IEEPA refund partner files it. For a mid-sized importer with 2,000-plus entry lines spread across base, 232, 301, and IEEPA codes, the first question is not "how do I file" but "which of my lines actually carried IEEPA duty," and that is a code-reading exercise, not a filing one.
Review secondary HTS codes and Chapter 99 filing alongside the primary code so tariff overlays are filed in the correct sequence.
GingerControl's IEEPA refund service sorts entries by refund route and deadline and prepares the refund file; our licensed IEEPA refund partner files it. GingerControl does not file CAPE declarations, protests, or Court of International Trade complaints, and it is not a licensed customs broker. The mapping below is the analysis an importer or their broker does before anyone files anything.
Why IEEPA duties live in Chapter 99, not on your base code
Chapters 1 through 98 of the Harmonized Tariff Schedule classify the goods themselves: a cotton t-shirt, a lithium battery, a steel bracket. Chapter 99 is different. It is a layer of temporary, policy-driven duties that attach on top of the base classification through a second HTS line on the same entry. Section 232, Section 301, Section 122, and IEEPA all live in Chapter 99. That is exactly why so many importers underestimated their IEEPA exposure: the base code looked normal, and the extra duty was hiding one line down.
Each IEEPA action was implemented by adding new subheadings to Subchapter III of Chapter 99, with the operative country lists, rates, and exceptions written into U.S. Note 2 to that subchapter. When an entry was filed, the broker declared the base code plus the applicable 9903 secondary code, and CBP assessed the additional ad valorem duty against the 9903 line. So the question "which HTS codes carry IEEPA duties" has a precise answer: the 9903.01 and 9903.02 subheadings, read against the notes that define their scope.
GingerControl's Tariff Calculator shows each duty layer for an HTS code and entry date: the base MFN rate, each Section 232 and 301 line and other Chapter 99 lines, with Section 122 only for entries dated February 24 to July 23, 2026. The Chapter 99 layers surface before entry rather than at liquidation. That is the same stack a licensed broker assembles by hand across multiple government sources.
The two IEEPA code families: 9903.01 vs 9903.02
There are two families, and they answer different policy questions. Mixing them up is the most common error when importers try to total their own exposure.
| IEEPA code family | What it covers | Legal trigger | Typical rate range | Plain-language label |
|---|---|---|---|---|
| 9903.01.xx | Trafficking and emergency measures: Northern Border (Canada), Southern Border (Mexico), PRC synthetic opioids (China), plus later Venezuela-oil-nexus and Brazil/India additions | National-emergency declarations on fentanyl, migration, and specific country conduct | 10% to 40% | "Fentanyl / trafficking tariffs" |
| 9903.02.xx | Country-specific reciprocal "trade deficit" tariffs across 60-plus countries | Executive Order 14257 reciprocal-tariff regime | 10% baseline up to ~41% | "Reciprocal tariffs" |
A few anchor codes worth recognizing on an entry, drawn from the HTSUS and CBP guidance:
- 9903.01.20 and 9903.01.24: the PRC synthetic-opioid (fentanyl) measures on products of China and Hong Kong, later cut to a 10% additional duty effective November 10, 2025. (9903.01.01 is the Mexico heading and 9903.01.10 the Canada heading.)
- 9903.01.25: the worldwide reciprocal baseline as originally implemented in spring 2025, before the country-specific structure took over.
- 9903.01.26 through 9903.01.33: exception codes (for example, the Canada and Mexico carve-outs) that excepted qualifying goods from the reciprocal duty.
- 9903.02.02 through 9903.02.71: the country-specific reciprocal subheadings (Afghanistan, Angola, Bangladesh, and so on), implemented under EO 14257 and effective August 7, 2025, each with its own rate set in U.S. Note 2(v) to Subchapter III.
Quotable insight: The single most expensive misread in IEEPA refund prep is treating Chapter 99 as one bucket. Only the 9903.01 and 9903.02 lines are IEEPA. An importer who sweeps in their 9903.88 Section 301 lines or 9903.80 Section 232 lines overstates the claim and invites a CBP rejection; an importer who scans only for "reciprocal" and ignores the 9903.01 fentanyl lines understates it. Eligibility is decided code by code, not by the word "tariff."
A practical caution: third-party "IEEPA code list" pages disagree with each other on which specific subheading maps to which country and rate, because the codes and rates were amended repeatedly through 2025. The authoritative mapping for any given entry is the HTSUS subheading and U.S. Note 2 in effect on that entry's date, cross-referenced with the CBP CSMS message that implemented it. Do not classify a refund off a blog table, including this one. Verify against the schedule and the entry date.
Chapter 99 codes that look like IEEPA but are not
This is where money gets left on the table or claims get bounced. Several Chapter 99 ranges are not IEEPA and are not part of the IEEPA refund.
| Chapter 99 range | Program | IEEPA? | Refundable through the IEEPA / CAPE process? |
|---|---|---|---|
| 9903.01.xx | IEEPA trafficking tariffs | Yes | Yes, subject to eligibility |
| 9903.02.xx | IEEPA reciprocal tariffs | Yes | Yes, subject to eligibility |
| 9903.88.xx | Section 301 (China) | No | No |
| 9903.80.xx / 9903.81.xx / 9903.85.xx | Section 232 (steel, aluminum, derivatives) | No | No |
| 9903.03.01 to 9903.03.11 | Section 122 temporary import surcharge (goods entered February 24 to July 23, 2026) | No | No, separate litigation track |
| AD/CVD case lines | Antidumping / countervailing duties | No | No |
Bottom line: For an importer or broker reconciling a 2025 entry history before filing, the value is in correctly separating the 9903.01/9903.02 lines from the 9903.88 and 9903.80 lines on the same entries, and from the Section 122 lines on entries made after February 23, 2026. GingerControl's IEEPA refund service prepares the refund file on that basis, sorted by refund route and deadline, so only the eligible lines are claimed. A "claim every Chapter 99 line" approach is best suited to no one; it overstates the refund and raises rejection risk.
Section 122 deserves a specific flag because it confuses even experienced teams. After the Supreme Court struck down IEEPA tariffs, much of that exposure was replaced by a 10% Section 122 surcharge on goods entered from February 24 to July 23, 2026, filed under its own Chapter 99 headings (9903.03.01 to 9903.03.11) and on its own legal track. On May 7, 2026 the Court of International Trade held the surcharge unlawful, but the remedy reached only the named plaintiffs, and on June 11, 2026 the Federal Circuit stayed that judgment pending the government's appeal. The surcharge expired at 12:01 a.m. EDT on July 24, 2026, and Section 301 forced-labor duties of 10% or 12.5% on products of 60 economies took its place the same minute. The takeaway for code-reading: a Section 122 line is not an IEEPA line, the IEEPA refund process will not refund it, and any Section 122 refund depends on that appeal.
How do you check whether your HTS lines carried IEEPA duty?
You do not need to guess from your product catalog. The record already exists in ACE. Here is the sequence, free of any tool:
- Pull the ES-003 report. In the ACE Portal, run the Entry Summary Line Tariff Details (ES-003) report for your importer-of-record number across the IEEPA rate period (roughly February 2025 through February 2026, with the bulk of reciprocal duty from spring 2025 onward). This gives you every entry line and every HTS code declared on it.
- Filter the Chapter 99 column for 9903.01 and 9903.02. Any line carrying a 9903.01.xx or 9903.02.xx secondary code carried IEEPA duty. Set aside 9903.88 (Section 301), 9903.80/81/85 (Section 232), and Section 122 lines; they are not part of this.
- Confirm the code against the entry date. Because the subheadings and rates changed through 2025, verify each 9903 code against the HTSUS subheading and U.S. Note 2 in effect on the entry date, and the CBP CSMS message that implemented that rate. A code that meant 25% in March may have meant 10% in November.
- Total the IEEPA duty by line. The dollar amount on each 9903.01/9903.02 line is the IEEPA duty paid. Sum it. That figure, not your total Chapter 99 duty, is your IEEPA refund exposure.
- Note liquidation status per entry. Whether each entry is unliquidated, liquidated within 80 days, or aged past 180 days determines which refund route is even available. That is the bridge from "which codes" to "how to file," covered in our process guides.
At a few dozen entries this is a careful afternoon. At thousands of lines across mixed codes and changing rates, it is the kind of repetitive, schedule-cross-referencing work that breaks down in a spreadsheet, which is the work GingerControl's IEEPA refund service takes on. For a first-pass number before you open the spreadsheet at all, our free IEEPA tariff refund estimator ballparks your refund exposure from entry value and rate.
The scale tells you why precision matters. CBP's own estimate, cited by the Court of International Trade, puts roughly $166 billion in IEEPA duties paid across about 53 million entries by some 330,000 importers. By October 2, 2026, CBP reported about $136.6 billion accepted for processing in CAPE and about $126 billion in refunds with interest certified and sent to Treasury. On a claim of that size, the difference between a clean 9903.01/9903.02 line list and a Chapter 99 free-for-all is the difference between a refund that clears and one that gets kicked back.
Where GingerControl fits in the code-reading step
GingerControl builds GingerLite, the app with the Classification Researcher and the Tariff Calculator, and runs five services delivered by people, one of them for IEEPA refunds. On the specific question this article answers, "which of my HTS lines carried IEEPA duty," two of these are relevant.
First, going forward, the Classification Researcher returns a 10-digit code with its GRI reasoning, Section and Chapter Note review and the CROSS rulings it read, and the Tariff Calculator shows each Chapter 99 layer for that code and entry date, so a new Chapter 99 layer is visible before entry rather than discovered at liquidation. Neither provides legal advice or replaces licensed customs expertise, and the 10-digit outputs are for the importer's licensed broker to review, not entries ready to file.
Second, the IEEPA refund service does the backward-looking version: it sorts an importer's entries by refund route and deadline, keeping the eligible 9903.01 and 9903.02 lines apart from the Section 232, Section 301 and Section 122 lines, and prepares the refund file. Our licensed IEEPA refund partner files it; GingerControl does not file it.
Here is how the three common ways to answer "which of my lines carried IEEPA duty" compare on the code-reading step itself, before any filing happens.
| Approach | Isolates 9903.01 / 9903.02 IEEPA lines | Separates 232 / 301 / 122 lines out | Ties each line to the rate on its entry date | Audit-ready eligibility documentation | Files the claim |
|---|---|---|---|---|---|
| GingerControl IEEPA refund service | Yes, from ES-003 data | Yes | Yes | A refund file sorted by route and deadline | No; our licensed refund partner files it |
| DIY ES-003 spreadsheet | Manual, error-prone at volume | Only if caught by hand | Manual schedule cross-reference | Varies | Importer or broker files |
| Filing-only refund provider | Often assumes the list is already correct | Varies | Usually out of scope | Focused on filing, not the basis | Yes (that is their scope) |
Bottom line: For an importer or broker with 2,000-plus mixed Chapter 99 lines who has not yet decided whether to file, the leverage is in the code-reading and separation work, not in the filing mechanics. GingerControl prepares that refund file, and our licensed IEEPA refund partner files it. A filing-only provider is best suited to importers whose eligible 9903.01/9903.02 line list is already verified and who just need the declaration submitted.
Frequently asked questions
What HTS codes carry IEEPA duties?
IEEPA duties were carried on Chapter 99 secondary codes in two ranges: 9903.01.xx for the trafficking tariffs (Canada, Mexico, and China fentanyl measures, plus later additions) and 9903.02.xx for the country-specific reciprocal tariffs. They have not been collected on goods entered since February 24, 2026. For a compliance manager reconciling a few thousand 2025 entry lines, the practical test is whether any line carries a 9903.01 or 9903.02 code. GingerControl's IEEPA refund service sorts those lines by refund route and deadline and prepares the refund file.
How do I know if my product was subject to IEEPA tariffs?
Your product's base HTS code does not tell you; the entry record does. Pull the ES-003 (Entry Summary Line Tariff Details) report from ACE and look for a 9903.01.xx or 9903.02.xx code on the line. For an importer with 100-plus SKUs sourced from multiple countries, exposure varies line by line because IEEPA was country-driven, not product-driven. GingerControl's IEEPA refund service works from the same record when it prepares the refund file, leaving out the Section 232 and 301 lines that are not IEEPA.
Is 9903.01 the same as 9903.02?
No. 9903.01.xx covers the trafficking and emergency IEEPA measures (fentanyl-related duties on China, plus the Canada and Mexico border measures and later additions), while 9903.02.xx covers the country-specific reciprocal "trade deficit" tariffs across 60-plus countries. For a CFO totaling recoverable cash, both are IEEPA and both are in scope, but they were assessed under different authorities and rates. Keep the two families as separate totals so the refund estimate can be checked line by line rather than taken as a lump guess.
Are Section 232 and Section 301 codes IEEPA codes?
No. Section 301 China tariffs use the 9903.88.xx range and Section 232 steel and aluminum tariffs use the 9903.80, 9903.81, and 9903.85 ranges. They are Chapter 99 codes, but they are not IEEPA and are not refundable through the IEEPA process. For a broker auditing a client's mixed entry history, sweeping these into an IEEPA claim is a common cause of CBP rejection. A refund file should list only the IEEPA 9903.01/9903.02 lines and leave the 232 and 301 lines out of the claim.
Does the IEEPA refund cover Section 122 tariffs?
No. Section 122 duties sit on their own Chapter 99 codes (9903.03.01 to 9903.03.11) and their own litigation track, and they apply only to goods entered from February 24 to July 23, 2026, after IEEPA collection had stopped. The Court of International Trade held the 10% Section 122 surcharge unlawful on May 7, 2026, but relief reached only the named plaintiffs, and on June 11, 2026 the Federal Circuit stayed that judgment pending the government's appeal. The surcharge expired on July 24, 2026. For an importer with entries in both periods, the two have to be handled separately: CAPE refunds IEEPA duty only, and any Section 122 refund depends on that appeal.
Review IEEPA refunds and customer tariff chargebacks against the sales contract when customers originally paid a separately identified tariff surcharge.
How do I find the exact rate a 9903 code charged on a given entry?
Because the IEEPA subheadings and rates were amended repeatedly through 2025, the rate depends on the entry date. Verify each 9903.01/9903.02 code against the HTSUS subheading and U.S. Note 2 to Subchapter III in effect on that date, plus the CBP CSMS message that set the rate. For a team reconciling entries across the whole 2025 rate period, the same code can mean different rates in different months. Checking each line against the rate in effect on its entry date is what makes the totals reconcile to the schedule.
Can GingerControl file my IEEPA refund for me?
No, GingerControl does not file it. Our IEEPA refund service sorts your entries by refund route and deadline and prepares the refund file, and our licensed IEEPA refund partner files it. Otherwise the CAPE declaration, any protest under 19 U.S.C. 1514, and any Court of International Trade complaint are filed by the importer or their licensed customs broker or counsel. Determining specific classifications beyond six digits and filing entry documents is customs business reserved to licensed brokers under CBP rulings HQ H290535 and HQ H350722, and GingerControl is built to support that work, not replace it.
Reading your IEEPA-bearing lines before you build a refund claim
If you paid duties in 2025 and you are deciding whether to pursue a refund, the first move is not picking a filing route, it is reading your own entry record and separating the 9903.01 and 9903.02 IEEPA lines from the Section 232 and Section 301 lines sitting next to them, and from any Section 122 lines on entries made after February 23, 2026. GingerControl's IEEPA refund service sorts your entries by refund route and deadline and prepares the refund file, leaving out the Section 232, Section 301 and Section 122 lines; our licensed IEEPA refund partner files it. See how the IEEPA refund service works →
GingerControl's services, including the IEEPA refund service and a 30-minute compliance audit, are open to any company, whether or not it uses GingerLite or GingerOS. Talk to our team →
References
- U.S. Supreme Court, Learning Resources, Inc. v. Trump, No. 24-1287 (Feb. 20, 2026)
Data cited: 6-3 decision holding the President lacks authority to impose tariffs under IEEPA; basis for refund claims
Source: Learning Resources, Inc. v. Trump, slip op. (Feb. 20, 2026)
Published: February 20, 2026 - U.S. Customs and Border Protection, International Emergency Economic Powers Act (IEEPA) Duty Refunds
Data cited: CAPE refund process; eligibility framework; refund administration under the CIT order
Source: CBP, IEEPA Duty Refunds
Published: 2026 (last modified September 30, 2026) - U.S. Customs and Border Protection, CSMS #68396594, AVAILABLE NOW: Consolidated Administration and Processing of Entries (CAPE) for IEEPA Refunds
Data cited: CAPE Phase 1 launch April 20, 2026; eligibility limited to certain unliquidated entries and entries within 80 days of liquidation; 9903.01/9903.02 IEEPA line requirement
Source: CBP CSMS #68396594
Published: April 2026 - U.S. Customs and Border Protection, IEEPA Frequently Asked Questions
Data cited: 9903.01 (trafficking/fentanyl) vs 9903.02 (reciprocal) Chapter 99 code structure; declaration of secondary codes
Source: CBP, IEEPA Frequently Asked Questions
Published: 2026 - BDO, IEEPA Tariff Refunds: Key FAQs for Importers
Data cited: 9903.01.xx (Northern Border, Southern Border, PRC synthetic opioids, Venezuela, Brazil/India) vs 9903.02.xx (reciprocal, 60+ countries) breakdown; rate ranges; key dates
Source: BDO, IEEPA Tariff Refunds: Key FAQs for Importers
Published: 2026 - Norton Rose Fulbright, CBP issues tariff refund instructions
Data cited: CIT order directing administrative refunds
Source: Norton Rose Fulbright, CBP issues tariff refund instructions
Published: 2026 - John S. Connor, Additional Details for Country-Specific Reciprocal Tariffs
Data cited: country-specific reciprocal subheadings 9903.02.02 through 9903.02.71 under EO 14257, effective August 7, 2025; U.S. Note 2(v) to Subchapter III of Chapter 99
Source: John S. Connor, Additional Details for Country-Specific Reciprocal Tariffs
Published: 2025 - BDO, U.S. Court of International Trade Invalidates Section 122 Tariffs
Data cited: CIT May 7, 2026 ruling on the 10% Section 122 tariff; remedy limited to named plaintiffs
Source: BDO, U.S. Court of International Trade Invalidates Section 122 Tariffs
Published: May 2026 - U.S. Customs and Border Protection, CSMS #67834313, guidance on Executive Order 14389, Ending Certain Tariff Actions
Data cited: IEEPA duties no longer collected for goods entered on or after 12:00 a.m. eastern time on February 24, 2026; IEEPA HTSUS numbers inactive in ACE from that date
Source: CBP CSMS #67834313
Published: February 22, 2026 - U.S. Court of International Trade, Freestyle World, Inc. v. CBP, No. 26-01088: Declaration of Brandon Lord (ECF 58) and Opinion and Order on class certification (ECF 61)
Data cited: about $166 billion in IEEPA duties on 53 million entries by roughly 330,000 importers (CBP estimate cited by the court); about $136.6 billion accepted in CAPE and about $126 billion certified and sent to Treasury as of October 2, 2026
Source: Lord declaration and Opinion and Order
Published: October 6 and October 8, 2026 - U.S. Court of Appeals for the Federal Circuit, State of Oregon v. Trump, Nos. 2026-1804, 2026-1805, order granting stay pending appeal
Data cited: CIT Section 122 judgment stayed pending appeal from June 11, 2026
Source: Federal Circuit order (copy)
Published: June 11, 2026 - Federal Register, USTR, Notice of Actions in Section 301 Investigations, Forced Labor, 91 FR 47318
Data cited: 10% or 12.5% on products of 60 economies from 12:01 a.m. ET July 24, 2026
Source: Federal Register
Published: July 28, 2026 - U.S. International Trade Commission, Harmonized Tariff Schedule, Revision 21 (2026), chapter 99
Data cited: 9903.01.01 (Mexico), 9903.01.10 (Canada), 9903.01.20 and 9903.01.24 (China and Hong Kong); Section 122 headings 9903.03.01 to 9903.03.11 expired at the close of July 23, 2026
Source: hts.usitc.gov
Retrieved: October 10, 2026
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Reviewed by Michael Weick, LCB / CCS
