The IEEPA layer
Energy and energy products were in Annex II and exempt from the reciprocal tariff. Solar modules from Southeast Asia paid the reciprocal rates of their origin countries, 10 percent from April 5, 2025 and country rates from August 7, 2025. Check your HTS codes against Annex II.
What is not refundable
- AD/CVD. Commerce issued final antidumping and countervailing duty determinations on April 21, 2025 for crystalline silicon photovoltaic cells from Cambodia, Malaysia, Thailand, and Vietnam.
- Section 301. Chinese solar cells at 50 percent from September 27, 2024, and polysilicon and wafers at 50 percent from January 1, 2025.
- Section 201. The solar safeguard expired February 6, 2026.
AD/CVD entries awaiting liquidation instructions were also excluded from CAPE. See excluded entry types.
Records to have ready
- Duty breakdown by entry line
- AD/CVD case numbers, if any
- 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.