Section 301 Tariff Refunds After the IEEPA Ruling: Untangling Two Duty Regimes on the Same Entry

When the Supreme Court struck down the IEEPA tariffs in February 2026, a lot of importers assumed their China duty problems were solved. Then they looked at their ACE portal data and realized the picture was messier. On a typical entry of Chinese goods filed in 2025, the duty column can show three separate charges: the base HTS rate, a Section 301 additional duty tied to a List 1 through List 4A code, and an IEEPA tariff layered on top. The IEEPA portion is now refundable. The Section 301 portion is not affected by that ruling at all. Sorting out which line item is which is the first real step in any import duty refund project for China-origin merchandise, and it is where a surprising number of claims go sideways.

Why Section 301 Duties Survived the IEEPA Ruling

Section 301 tariffs rest on a different legal foundation than IEEPA. They come from the Trade Act of 1974, which gives the U.S. Trade Representative authority to impose duties in response to foreign trade practices. The Supreme Court's February 2026 decision addressed IEEPA-based tariffs, the emergency authorities invoked for fentanyl-related duties on China, Mexico, and Canada and for the reciprocal tariffs on other trading partners. It did not disturb Section 301. Those duties remain in force, and the exclusions process that has always governed them remains the primary recovery path.

That distinction matters because importers who file an IEEPA tariff refund claim through the CAPE portal and assume it covers everything will recover less than they expect. The claim only reaches the IEEPA line. Section 301 recovery runs through a different process, with different deadlines and different evidence requirements. Treating them as one item is the most common mistake in this area right now.

Reading a Dual-Duty Entry Summary Correctly

CBP Form 7501 lists each duty component separately. On a dual-duty entry you will typically see the Chapter 99 subheading for the Section 301 action (9903.88.01 and its siblings) on one line and a separate Chapter 99 subheading for the IEEPA duty on another. The HTS code of the underlying merchandise, say a furniture item under heading 9403 or an electronic component under 8542, appears as the commodity line. The duty amounts tied to each Chapter 99 line are calculated independently and posted to separate accounts.

When you pull Trade Activity Reports or an ACE Entry Summary query, confirm you are looking at each Chapter 99 line separately. A single lumped duty figure will not tell you what is refundable. The refundable IEEPA portion is only the amount tied to the IEEPA subheading, plus the statutory interest that accrues on it. For many importers of Chinese goods, that is a meaningful number, and it is the one the CAPE portal is set up to process.

Section 301 Recovery Runs on Exclusions, Not on the IEEPA Refund Window

Section 301 has its own recovery mechanism, and it has always been exclusion-based. If a product fell within a granted exclusion at the time of entry, the additional duty should not have been collected, and you can pursue a refund. If an exclusion expired before your entry date, the duty is generally owed. Expired exclusions do not become refundable because IEEPA was struck down. The two regimes do not cross over.

That means the practical question for Section 301 is not whether to file a claim, but whether your specific product and entry date match a live exclusion at the time of import. This is a date-sensitive, product-specific analysis. A CNC machine tool under one HTS line may qualify while a similar tool under a neighboring line does not. Getting this wrong wastes time and can complicate the IEEPA claim that is otherwise clean.

• Verify the Chapter 99 subheading on every entry line before you assume a duty is IEEPA-based.
• Match each Section 301 line to the exclusion list in effect on the entry date, not the date you noticed the issue.
• Keep the IEEPA refund claim and any Section 301 exclusion claim as separate workstreams with separate documentation.
• Confirm the importer of record number is consistent across both claims, since that is the entity CBP pays.

The Refund Deadlines You Are Actually Working Against

IEEPA refunds have two hard deadlines. Fentanyl-related tariffs on China, Mexico, and Canada must be claimed by February 4, 2027. Reciprocal tariffs on other countries must be claimed by April 5, 2027. These are not rolling deadlines. They do not extend because you were busy or because your broker changed systems.

Section 301 exclusion claims follow a different procedural path and are not governed by those two dates, but they still have practical limits tied to liquidation status and the protest or post-summary correction window. If an entry is already liquidated and the protest period has closed, recovery options narrow considerably. Importers who paid both duty types should map their Section 301 exposure and their IEEPA exposure on the same spreadsheet so nothing falls through the gap between the two timelines.

What Most Importers Are Missing

CBP has processed roughly $121.75 billion in IEEPA claims to date, and about 93.5 percent of eligible importers have not yet filed. A large share of those non-filers are importers who paid both Section 301 and IEEPA duties and assumed the two were a single issue. They are not. The IEEPA money is refundable now through the CAPE portal, paid by ACH within roughly 60 to 90 days including statutory interest. The Section 301 money is only refundable if your product and entry date fit an exclusion.

You can untangle this yourself. Pull your entries from ACE, separate the Chapter 99 lines, and check each Section 301 line against the exclusion lists. It is tedious but doable. What you cannot do is let the February 4, 2027 and April 5, 2027 deadlines pass while you sort it out, because there is no late filing window for the IEEPA portion.

Check How Much You Can Recover

Tarisol connects U.S. importers with licensed specialists who file IEEPA tariff refund claims through the CAPE portal. Fees are success-based, with no upfront cost. If you imported Chinese-origin goods and paid both Section 301 and IEEPA duties, the fastest way to find out what is recoverable is to run your import data through a specialist who can separate the two duty streams. Start with a no-cost eligibility check and see the numbers before you commit to anything.