How to Reconcile IEEPA Tariff Refunds With Section 232 and Section 301 Duties on the Same Entry

When the Supreme Court struck down the IEEPA tariffs in February 2026, a lot of importers assumed the whole duty bill on their 2025 entries had been invalidated. That is not what happened. A single CBP Form 7501 can carry four or five different duty programs stacked on the same line, and only one of them was ruled unconstitutional.

If you file an IEEPA tariff refund claim that includes Section 232, Section 301, antidumping, or countervailing duties, CBP will reject the claim, or worse, it will sit in review while your real refundable amount ages past the deadline. This post explains how to pull the layers apart.

Why Entries Carry Multiple Duty Programs at Once

Duty liability on an entry line is not a single number. It is a stack. A steel bracket from China entered in 2025 might carry: a general or Column 1 duty rate under the Harmonized Tariff Schedule, a Section 301 List 3 or List 4A additional duty of 25 percent or 7.5 percent, a Section 232 derivative steel duty of 25 percent, and an IEEPA fentanyl tariff of 20 percent. Four separate legal authorities, four separate line items on the 7501.

Only the IEEPA layer was invalidated. Section 232 rests on national security authority under Section 232 of the Trade Expansion Act of 1962. Section 301 rests on Section 301 of the Trade Act of 1974. Those authorities were untouched by the Supreme Court's ruling, and the agencies have said so repeatedly.

The Three Layers You Need to Identify Before You File

Layer 1: Ordinary Customs Duties

Your base HTS rate is almost never refundable through the IEEPA process. It is owed, it was owed at entry, and it stays owed. The one exception is a classification error or a preference claim you can still perfect, which is a separate protest action under 19 U.S.C. 1514, not an IEEPA refund.

Layer 2: Section 232 and Section 301 Additional Duties

These are the layers most commonly confused with IEEPA. They appear on the same 7501 with similar-looking duty codes. Section 301 codes typically start with 9903. Section 232 codes typically start with 9903 as well but reflect different subheadings and often carry a Chapter 99 footnote about derivative or primary articles. Read the subheading, not the rate, to tell them apart.

Neither is refundable through CAPE. If your IEEPA tariff refund claim pulls a Section 301 amount into it, expect a request for information and a delay.

Layer 3: IEEPA Tariffs

This is the refundable layer. It covers the fentanyl-related tariffs on China, Mexico, and Canada with a filing deadline of February 4, 2027, and the reciprocal tariffs on other trading partners with a deadline of April 5, 2027. CBP has processed roughly 121.75 billion dollars in claims so far, and about 93.5 percent of eligible importers have still not filed.

How to Match the Duty Codes to the Right Program

• Open the ACE Portal and pull the entry summary data for each affected entry. You need the 7501 line detail, not a total duty figure.
• For every line, capture the Chapter 99 subheading, the duty rate applied, and the dollar amount assessed.
• Sort those subheadings into three buckets: general rate, Section 232 or 301, and IEEPA. Do not group by rate alone. A 25 percent line can be either 232 or 301.
• Confirm the IEEPA subheadings against the Federal Register notice that imposed each order. The country and date of entry determine which order applies.
• Reconcile the totals. The IEEPA bucket should equal the amount you claim. If it does not, you have a coding error.

Where Importers Get This Wrong

The most common mistake is claiming the full duty paid on the entry. The second most common is claiming based on the line total instead of the per-unit rate times quantity, which produces a mismatch on review. The third is failing to net out any drawback already taken on the same goods, because you cannot recover twice on the same duty.

A fourth mistake is subtler. Some entries have IEEPA tariffs and Section 301 duties that were assessed on the same value. If you claim the IEEPA amount but your documentation shows a combined rate, the specialist reviewing your file may flag the whole entry. Clean documentation of the split avoids this.

What a Clean Claim Looks Like

A defensible IEEPA tariff refund claim ties each claimed dollar to a specific entry line, a specific IEEPA subheading, and a Federal Register citation. It excludes Section 232 and Section 301 amounts by design, not by accident. It reconciles to the ACE Portal data CBP already holds on your imports, which means the numbers should agree on first read.

Refunds are issued by ACH within roughly 60 to 90 days of approval, including statutory interest. Interest is calculated from the date of deposit, which is another reason to get the underlying amount right the first time. An amended claim restarts part of the clock.

Act Before the Deadlines, Not at Them

You have two deadlines, and they are not the same date. February 4, 2027 covers fentanyl tariffs on China, Mexico, and Canada. April 5, 2027 covers reciprocal tariffs on other countries. If you imported from multiple sources under both programs, you are looking at two separate claim populations with different clocks.

Start with reconciliation, because it takes longer than filing. Most of the work is reading entries and sorting subheadings, and that work has to be done before anything goes into CAPE. With the majority of eligible importers still unfiled, the practical risk is not a rejected claim. It is a missed window.

Check Your Eligibility With Tarisol

Tarisol connects U.S. importers with licensed specialists who file IEEPA tariff refund claims through CBP's CAPE portal. Fees are success-based, with no upfront cost. If you paid IEEPA tariffs on China, Mexico, Canada, or reciprocal-tariff countries and you also paid Section 232 or Section 301 duties on the same entries, a specialist can separate the layers for you and file only what is actually recoverable. Check your eligibility today.