IEEPA vs Section 232, Section 301, and AD/CVD: Which Duties Are Refundable?

Only IEEPA duties are being refunded. How to tell IEEPA duties apart from Section 232, Section 301, antidumping and countervailing duties, Section 122, and ordinary duties on your entries.

By the TariffClarity editorial team. Published September 24, 2026

The most common reason a refund looks short is that the estimate included duties that are not IEEPA duties. Here is how the main types differ.

Duty typeWhat it isRefunded through CAPE?
IEEPA dutiesThe 2025 duties on China, Canada, Mexico, Brazil, India, and the reciprocal tariff, reported under Chapter 99 numbers 9903.01.xx and 9903.02.xxYes, for eligible entries
Section 232National security duties on steel, aluminum, autos and parts, copper, timber and lumber, and othersNo
Section 301Duties responding to trade practices, most notably on many goods from ChinaNo
AD/CVDAntidumping and countervailing duties under specific ordersNo
Section 122The 10 percent surcharge from February 24 to July 24, 2026No
Ordinary (MFN) dutiesThe normal tariff rate for the HTS codeNo

How they interacted

  • Goods subject to Section 232 were generally excluded from the reciprocal tariff, so the same line rarely paid both. Steel and aluminum derivatives from June 4, 2025 were the main exception, paying Section 232 on metal content and reciprocal duty on the rest.
  • Section 301 and IEEPA duties stacked on Chinese goods.

How to check your entries

Filter the ES-003 report in ACE on 9903.01.xx and 9903.02.xx to see only IEEPA lines. See our ACE reports guide.

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

Sources

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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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