Which HTS Codes Carry IEEPA Duties (and How to Check Yours)

Which HTS codes carry IEEPA duties?

IEEPA duties ride 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.

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 post-2026 refund process. Section 232 (9903.80/81/85), Section 301 (9903.88), and Section 122 codes are not IEEPA and not part of that refund.

TL;DR

IEEPA duties never sit on your base HTS code. They are 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 and, under a Court of International Trade order, began refunding roughly $166 billion paid across about 53 million entries. GingerControl is a trade compliance AI platform that helps importers, brokers, and finance teams read their own entry history; its IEEPA Refund Recovery service segments an ES-003 export by these exact 9903 codes so the importer or their licensed broker knows which lines are eligible before filing. 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.

Last updated: June 2026

GingerControl provides research and advisory support on IEEPA exposure: it identifies which HTS lines carried IEEPA duty and documents the basis. It 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 HTS Classification Researcher returns the full tariff stack alongside a classification, base MFN plus Section 301, Section 232, Section 122, and Chapter 99, so the IEEPA layer surfaces at classification time 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:

9903.01.10 and the China fentanyl series: the PRC synthetic-opioid measures, which CBP later reduced to a 10% additional duty on most products of China effective November 10, 2025.
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
Section 122 reciprocal codes	Section 122 "temporary global tariff"	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, 9903.80, and Section 122 lines on the same entries. GingerControl's IEEPA Refund Recovery service does that segmentation from the ES-003 data so the importer or their licensed broker files only the eligible lines. 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 effectively replaced by Section 122 reciprocal duties, which sit on their own Chapter 99 codes and their own legal track. On May 7, 2026 the Court of International Trade held the 10% Section 122 "temporary global tariff" unlawful, but the remedy reached only the named plaintiffs, and the Federal Circuit entered an administrative stay on May 12, 2026 while the appeal proceeds. The statutory Section 122 sunset is July 24, 2026 absent a congressional extension. The takeaway for code-reading: a Section 122 line is not an IEEPA line, the IEEPA refund process will not refund it, and it has to be preserved separately.

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 gap GingerControl's refund advisory is built to close.

The scale tells you why precision matters. CBP data cited by counsel puts roughly $166 billion in IEEPA duties paid across about 53 million entries by some 330,000 importers, with CBP reporting that around $89 billion in refunds has been accepted for processing and about $22 billion disbursed under the Court of International Trade's order. 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 is a trade compliance AI platform that helps importers, exporters, and customs brokers classify products, calculate the full tariff stack, and recover overpaid duties. On the specific question this article answers, "which of my HTS lines carried IEEPA duty," two parts of the platform are relevant.

First, the HTS Classification Researcher returns the full tariff stack with every classification (base MFN plus Section 301, 232, 122, and Chapter 99 entries), so going forward the IEEPA-style Chapter 99 layer is visible at classification time rather than discovered at liquidation. It follows the same reasoning process a licensed customs broker uses, GRI analysis, Section and Chapter Note review, and CROSS ruling research, and produces audit-ready documentation that supports the decision. It does not provide legal advice or replace licensed customs expertise, and its 10-digit outputs are research for the importer or their broker to review, not entries ready to file.

Second, the IEEPA Tariff Refund Recovery service does the backward-looking version: it segments an importer's ES-003 entry history by 9903 code and liquidation status, isolating the eligible 9903.01 and 9903.02 lines and separating them from Section 232, Section 301, and Section 122 lines, then documents the routing so the importer or their licensed broker or counsel can file each entry through the correct channel. GingerControl performs the research and advisory analysis; the CAPE declaration, the protest, and any CIT complaint are filed by the importer or their licensed broker.

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 (research / advisory)	Yes, from ES-003 data	Yes	Yes	Yes	No, by design (importer or broker files)
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 supplies that analysis as research the importer or their licensed broker reviews and acts on. 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 are 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. 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 Recovery service segments your ES-003 export by exactly these codes so you or your broker can see eligible lines at a glance.

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 research support reads the ES-003 and flags every IEEPA-bearing line, separating them from 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. GingerControl's advisory analysis tallies both families separately so the recovery estimate is auditable rather than 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. GingerControl's segmentation isolates the IEEPA 9903.01/9903.02 lines and leaves the 232 and 301 lines out of the claim.

Does the IEEPA refund cover Section 122 reciprocal tariffs?

No. Section 122 reciprocal duties sit on their own Chapter 99 codes and their own litigation track. The Court of International Trade held the 10% Section 122 tariff unlawful on May 7, 2026, but that ruling is stayed on appeal at the Federal Circuit and the duty is set to sunset July 24, 2026. For an importer carrying both IEEPA and Section 122 exposure, the two have to be handled separately. GingerControl's Compliance Radar separates the two and tracks each so an IEEPA channel is never assumed to refund a Section 122 payment.

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. GingerControl's research support ties each line to the rate in effect on its entry date so the totals reconcile to the schedule.

Can GingerControl file my IEEPA refund for me?

No. GingerControl provides research and advisory support only: it identifies which HTS lines carried IEEPA duty, segments them by code and liquidation status, and produces audit-ready documentation of the analysis. 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, Section 301, and Section 122 lines sitting next to them. GingerControl's IEEPA Tariff Refund Recovery service segments your ES-003 entry history by these exact Chapter 99 codes and by liquidation status, totals the eligible IEEPA duty line by line against the rate in effect on each entry date, and documents the analysis so you or your licensed broker can file a clean claim. Check which of your lines carried IEEPA duty →

GingerControl is not just a tool. We work with importers and trade compliance teams on process consulting, digital transformation strategy, and end-to-end custom system development, starting with a free 30-minute compliance audit. Talk to our team →

References

[REF 1] 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

[REF 2] 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 (updated through June 2026)

[REF 3] 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

[REF 4] 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

[REF 5] 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

[REF 6] Norton Rose Fulbright, CBP issues tariff refund instructions Data cited: approximately $166 billion paid across 53 million entries by ~330,000 importers; ~$89 billion accepted and ~$22 billion disbursed; CIT order directing administrative refunds Source: Norton Rose Fulbright, CBP issues tariff refund instructions Published: 2026

[REF 7] 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

[REF 8] 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; Federal Circuit administrative stay May 12, 2026; July 24, 2026 statutory sunset Source: BDO, U.S. Court of International Trade Invalidates Section 122 Tariffs Published: May 2026

Which HTS Codes Carry IEEPA Duties (and How to Check Yours)