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9903.01.01 (Ended): IEEPA Mexico Fentanyl 25% Tariff Heading

Published: October 19, 2026  ·  6 min read
9903.01.01 (Ended): IEEPA Mexico Fentanyl 25% Tariff Heading
Photo: Mariana Basurto / Pexels

Key Points

On this page

  1. What 9903.01.01 was and when it ended
  2. Products and countries in scope
  3. The 25 percent rate and its effective window
  4. Exemption headings and how they interacted with 9903.01.01
  5. How the heading appeared on a customs entry
  6. Refund path for duties deposited under 9903.01.01
  7. What importers should do
  8. Key references

HTS heading 9903.01.01 was a Chapter 99 special-program code that added a 25 percent duty to most articles the product of Mexico, authorized by Executive Order 14194, as amended. It was active from 2025-03-04 through 2026-02-23 and ended on 2026-02-24. It is no longer in force. The links throughout this article go to the primary documents: the executive order, the official tariff schedule, and CBP guidance pages themselves. Read the source.

What 9903.01.01 was and when it ended

Heading 9903.01.01 was created under the International Emergency Economic Powers Act (IEEPA) as part of the Mexico Fentanyl program. The legal basis was Executive Order 14194, as amended. The heading's official text read: "Except for products described in headings 9903.01.02, 9903.01.03, 9903.01.04 and 9903.01.05 articles the product of Mexico, as provided for in U.S. note 2(a) to this subchapter."

The heading was active for just under one year. It took effect on 2025-03-04 and its final day of applicability was 2026-02-23. As of 2026-02-24, the heading was terminated and is no longer in force. Entries filed on or after 2026-02-24 did not carry this heading.

Products and countries in scope

9903.01.01 applied exclusively to articles the product of Mexico. No other country of origin triggered this heading. The scope was broad: subject to the exclusions described below, the heading covered the general universe of Mexican-origin merchandise as provided for in U.S. note 2(a) to the Chapter 99 subchapter in force during the applicable window.

Importers needed to confirm country of origin under CBP's substantial-transformation standard. Goods that merely transited Mexico, or that were processed there without a substantial transformation, were not necessarily "products of Mexico" for tariff purposes. Confirm the applicable origin rules in the HTSUS or with your broker if origin was in question.

The 25 percent rate and its effective window

The duty rate imposed by 9903.01.01 was 25 percent ad valorem. That rate applied to all in-scope Mexican-origin goods entered for consumption, or withdrawn from warehouse for consumption, from 2025-03-04 through 2026-02-23. The heading imposed an additional duty on top of the normal column 1 general rate for the underlying Chapter 1-97 classification; the two rates stacked.

No rate other than 25 percent applied under this specific heading. The facts block does not identify any phased reduction or escalation within the window, so importers should treat the 25 percent as flat across the entire operative period.

Exemption headings and how they interacted with 9903.01.01

Four companion headings carved out specific categories of Mexican-origin goods from 9903.01.01's reach:

Products that fell within any of those four headings were excluded from 9903.01.01 by the heading's own text. If a product was described in one of the companion headings, the 25 percent rate did not apply through 9903.01.01. Importers should check the current HTSUS Chapter 99 and the companion heading articles (see Key references) to understand what each exemption covered. The facts block does not detail the scope of 9903.01.02 through 9903.01.05, so confirm their precise text in the HTSUS or with your broker.

For a closely parallel program involving Canadian-origin goods, see the related article on 9903.01.10 (Ended): IEEPA Canada Fentanyl Tariff Heading Explained.

How the heading appeared on a customs entry

Chapter 99 codes like 9903.01.01 rode alongside, not instead of, the underlying Chapter 1-97 classification. On a CBP Form 7501, a dutiable Mexican-origin entry looked like this in practice:

Both duties were computed on the entered value and added together. If the companion exemption headings applied, the broker would have reported the relevant exemption heading (9903.01.02, .03, .04, or .05) instead of 9903.01.01. Entries that omitted 9903.01.01 for in-scope Mexican goods during the 2025-03-04 to 2026-02-23 window may have been under-declared and could face CF-28 or CF-29 requests from CBP.

For a broader look at how Chapter 99 codes were organized in 2026, see the 2026 tariff code overview.

Refund path for duties deposited under 9903.01.01

Because 9903.01.01 was an IEEPA heading, duties deposited while it was in force were refundable through CBP's CAPE (Customs Automated Protest and Entry) process in ACE. The heading ended on 2026-02-24, so duties collected during the 2025-03-04 through 2026-02-23 window are the amounts in question.

To prepare a claim, an importer needed:

The step-by-step process for pursuing a refund is on the IEEPA tariff refund guide. Common reasons CAPE submissions are rejected, and how to fix them, are covered on the CAPE errors page. If you use ACE to manage your entry data, the article on the ACE Portal application and account setup explains what data is accessible and how to pull the records you need.

What importers should do

Key references


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About the Author

Franz Brotzen, CustomsGenius CEO & Founder. Franz is a published researcher on U.S. trade policy. He has worked at think tanks in Washington DC and Tokyo, where his academic publications focussed on tariffs and legal compliance. Franz received his JD from Harvard Law School.

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