Last reviewed: October 6, 2026. Reading time: about 10 minutes.
This question usually comes from the wrong direction. Importers search for a list of product categories, electronics, apparel, furniture, expecting some categories to qualify and others not to. That is not how eligibility actually works. Almost any product, under almost any HTS classification, could have carried an IEEPA charge, depending on where it came from and when it was imported. What actually determines eligibility is a separate, secondary code stamped onto the entry alongside the product code, not the product code itself.
This picks up directly from our guide to which portion of your tariff is refundable, and goes one level more technical: the exact codes to look for on your own entry summary.
The short version: your product’s own HTS classification, the code describing what the item actually is, almost never determines IEEPA eligibility by itself. What matters is whether a secondary Chapter 99 code, specifically one starting with 9903.01 or 9903.02, appears on the same entry line. Those two code families are the IEEPA duty. Everything else in Chapter 99, including Section 301 and Section 232 codes, is not.
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In this guide
Why “which product” is the wrong question
Every imported product has a primary HTS classification, a code in Chapters 1 through 97 that describes what the item actually is, a bicycle, a t-shirt, a circuit board. That code almost never changed because of IEEPA. What changed is that CBP layered a second, separate code on top of it, from Chapter 99, the part of the tariff schedule reserved for temporary and special tariff actions. Your refund eligibility depends on that second code, not the first.
This is why a flat list of “qualifying products” does not really exist. The same bicycle imported from Country A during the IEEPA period might carry an IEEPA Chapter 99 code, while an identical bicycle from Country B, or imported a few weeks earlier or later, might not.
The two IEEPA code families
CBP’s own IEEPA FAQ confirms this structure directly, and law and tax firms advising importers consistently point to these same two prefixes when identifying refund-eligible duty lines. If a Chapter 99 code on your entry starts with either of these, that specific line is the one CAPE is built to remove and refund.
A few illustrative examples
These are a handful of codes reported in professional tariff guidance, shown to illustrate the pattern, not as a complete or current list. The exact codes and rates were amended repeatedly throughout 2025, so treat this as context, not a checklist to copy.
Do not file from a public code list. Multiple trade compliance sources explicitly warn that third-party IEEPA code reference pages disagree with each other, because the specific subheadings and rates were amended repeatedly through 2025. The only reliable source for your own entries is your own entry data, not a static article, including this one.
What is in Chapter 99 but not IEEPA
Not every code starting with 9903 is an IEEPA code. Chapter 99 is a shared home for several different temporary tariff authorities, and CBP's own guidance notes that entries, especially from China, commonly carry multiple Chapter 99 lines stacked together:
- Section 301 codes (commonly 9903.88.xx) for China-specific tariffs tied to earlier trade investigations. Not refundable.
- Section 232 codes for steel, aluminum and related derivative products. Not refundable.
- Antidumping and countervailing duty codes (commonly 9903.45.xx), assessed under a separate legal process. Not refundable.
- Section 122 and other temporary surcharge codes, which postdate the IEEPA collection period and are legally distinct. Not refundable.
This is exactly the mistake CBP has flagged as a common cause of rejected declarations, covered in our mistakes guide: sweeping every Chapter 99 line into a claim, rather than isolating specifically the 9903.01 and 9903.02 codes.
Exceptions that may mean you have no IEEPA code at all
Even goods from a country generally subject to IEEPA tariffs could have been exempt under specific exception codes CBP published alongside the main ones. A few patterns worth knowing:
- USMCA-qualifying goods from Canada and Mexico typically carried additional Chapter 99 codes specifically exempting them from both the IEEPA and reciprocal tariffs.
- Certain product categories, including goods already subject to Section 232 duties on autos, auto parts, copper, aluminum, steel and timber, had their own exemption codes from the IEEPA reciprocal tariff specifically.
- Country-specific exception codes existed too, for example separate exception provisions applied to qualifying goods of Canada, Mexico, China, Hong Kong and Macau under the reciprocal tariff structure.
If your entries show one of these exception codes instead of a 9903.01 or 9903.02 charge, that specific entry likely never paid an IEEPA duty in the first place, which means there is nothing to refund on it, not a missed opportunity.
How to find yours
- Pull your ES-003 report, or ask for one. If you have ACE Portal access, the ES-003 Entry Summary Line Tariff Details report, mentioned directly on CBP's own IEEPA page, can filter for entries carrying the IEEPA indicator.
- Ask your broker the specific question. A precise question gets a precise answer: “Do my entries from February 2025 through February 2026 include any HTS codes starting with 9903.01 or 9903.02?”
- Review CBP Form 7501 line by line. Look specifically under the Chapter 99 secondary classification lines, not the primary product HTS code, for either prefix.
- Separate what you find into two piles. 9903.01 and 9903.02 lines go in your refund claim. Every other Chapter 99 code, Section 301, Section 232, antidumping, countervailing, stays out.
- When in doubt, ask rather than assume. Given how often these codes were amended, a quick confirmation from your broker beats relying on any general list, including the examples above.
A message to send your broker
Hi [Name], could you check my entries from February 2025 through February 2026 and confirm which ones carry a Chapter 99 secondary code starting with 9903.01 or 9903.02? I want to separate those specifically from any Section 301, Section 232, or antidumping/countervailing codes before I look into a refund. Thank you.
Frequently asked questions
Not really. Eligibility is determined by a secondary Chapter 99 code on the entry, specifically one starting with 9903.01 or 9903.02, not by the underlying product category. Nearly any product classification could carry an IEEPA code depending on origin and timing.
9903.01 covers the IEEPA trafficking and fentanyl-related tariffs tied to China, Canada and Mexico. 9903.02 covers the broader IEEPA reciprocal, country-specific tariffs that took effect from April 2025.
No. 9903.88 is commonly used for Section 301 tariffs on China, a separate legal authority that is not part of the IEEPA refund program.
Treat any such list, including the examples in this guide, as illustrative rather than definitive. The specific codes and rates were amended repeatedly, and trade compliance professionals themselves note that third-party lists frequently disagree. Confirm your own entries directly.
Your entries may fall under one of the exception codes that exempted certain goods, such as USMCA-qualifying products, from IEEPA tariffs in the first place. If so, there is no IEEPA duty paid on that entry to refund.
Yes, this is common, especially for goods from China, which often carry both a 9903.88 Section 301 line and a 9903.01 IEEPA line on the same entry. Only the IEEPA line is refundable.
Confirmed your 9903.01 or 9903.02 codes?
Once you know which entries actually carried an IEEPA charge, the next step is finding out what you may be owed. Tariff Refund Agency offers a free eligibility check that takes about five minutes, with no commitment.
Start Your Free Eligibility Check
Affiliate disclosure: if you apply through this button, we may earn a commission from Tariff Refund Agency. Refund eligibility, amounts and timing depend on individual circumstances and are never guaranteed. Read our affiliate disclosure and disclaimer.
Sources and further reading
- Tariff Refunds Finder: IEEPA Tariff Refund: Are You Owed Money by CBP?
- Tariff Refunds Finder: Is Your Entire Tariff Refunded, or Just the IEEPA Portion?
- Tariff Refunds Finder: 5 Costly Mistakes That Can Delay Your CAPE Refund Claim
- Tariff Refunds Finder: Tariff Refund Eligibility Checklist for US Importers (2026)
- CBP: International Emergency Economic Powers Act (IEEPA) Frequently Asked Questions
- BDO: IEEPA Tariff Refunds, Frequently Asked Questions
Educational only. Tariff Refunds Finder is not CBP, U.S. Customs or a government agency, and this guide is not legal, tax or customs classification advice. HTS and Chapter 99 codes are complex and were amended repeatedly throughout 2025. Confirm your specific codes with a licensed customs broker before acting.
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