IEEPA Tariff Refunds for Chemical and Plastics Importers

Some chemicals and energy products were exempt from the reciprocal tariff under Annex II, and the list changed in September 2025. Whether a product paid IEEPA duty depends on its HTS code and entry date.

Reviewed September 24, 2026

Blue and yellow plastic resin pellets

How IEEPA tariffs hit chemicals and plastics

  • Annex II. The April 2025 reciprocal order exempted energy and energy products and certain critical minerals, among other categories, through Annex II.
  • September 8, 2025 changes. An order effective September 8, 2025 removed several items from Annex II, including aluminum hydroxide, certain resins, and silicones, so those products paid the reciprocal tariff from that date. It also added other items, including some critical minerals.
  • China. China-origin chemicals also paid the IEEPA duty tied to synthetic opioids unless exempt.

What to check

Check each HTS code against Annex II as it stood on the entry date. A product exempt in the spring may have paid reciprocal duty after September 8, 2025, and the reverse.

Records to have ready

  • HTS codes by product and entry dates
  • ES-003 and ES-022 reports

Sources

How we can help

We explain the general options for your situation in plain English, show you which ACE reports to pull, and email you a list of licensed customs brokers and attorneys who handle it. The review is free for importers. We do not file with CBP or give legal advice.

General information, not legal or customs advice. Facts last reviewed September 24, 2026. Confirm dates and options for your entries with a licensed professional.

General information, not legal advice. Tariff refund rules and court rulings are changing. Deadlines depend on your own entries. Confirm your options with a licensed customs broker or attorney. TariffClarity is not a law firm or customs broker.

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