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9903.01.10 (Ended): IEEPA Canada Fentanyl Tariff Heading Explained

Published: October 18, 2026  ·  6 min read
9903.01.10 (Ended): IEEPA Canada Fentanyl Tariff Heading Explained
Photo: Matt Barnard / Pexels

Key Points

On this page

  1. What heading 9903.01.10 was and when it ended
  2. Legal authority and program background
  3. Affected products and country scope
  4. Rate windows and effective dates
  5. How the heading appeared on an entry alongside companion exemptions
  6. What importers should do
  7. Key references

HTS 9903.01.10 was a Chapter 99 additional-duty heading created under the IEEPA Canada Fentanyl program. It applied an extra duty on most Canadian-origin goods from 2025-03-04 until it ended on 2026-02-23, with the heading formally terminated on 2026-02-24. As of October 18, 2026, 9903.01.10 carries no ongoing obligation. The information below describes what the heading did while it was active.

The links in this article go to the primary documents: the executive orders, the Harmonized Tariff Schedule, and official CBP pages themselves. Read the source.

What heading 9903.01.10 was and when it ended

Heading 9903.01.10 was terminated on 2026-02-24. From that date forward, the heading imposed no additional duty and appeared on no new entries. Its entire operative life ran from 2025-03-04 through 2026-02-23.

During that window, the heading was the catch-all additional-duty line for articles the product of Canada under the IEEPA Canada Fentanyl action. The official heading text read: "Except for products described in headings 9903.01.11, 9903.01.12, 9903.01.13, 9903.01.14 or 9903.01.15, articles the product of Canada, as provided for in U.S. note 2(j) to this subchapter."

If your entries fell between 2025-03-04 and 2026-02-23 and included Canadian-origin goods that did not qualify for one of the five companion exemption headings, 9903.01.10 was the line that added duty to your entry. Confirm the heading's historical text and note references in the Harmonized Tariff Schedule on hts.usitc.gov.

Legal authority and program background

The Canada Fentanyl action was authorized under the International Emergency Economic Powers Act. Executive Order 14193 created the framework, and Executive Order 14325 amended it. Both orders are published at the White House website. The Federal Register carried the implementing notices; the full text is searchable at federalregister.gov.

The program was separate from other IEEPA actions running concurrently, such as the global reciprocal tariff structure. Heading 9903.01.10 was specific to Canada and to the fentanyl emergency justification stated in those executive orders.

Affected products and country scope

The heading covered articles the product of Canada only. Country of origin, not country of export, controlled applicability. Goods transshipped through Canada but originating elsewhere were not within scope of 9903.01.10 on that basis alone, though other provisions may have applied. Confirm country-of-origin determinations with your broker or with CBP guidance at cbp.gov.

Companion exemption headings

Five headings explicitly carved goods out of 9903.01.10's reach:

Goods that properly used one of those five headings did not also carry 9903.01.10. If your entries used 9903.01.10 on goods that should have qualified for a companion exemption, that classification error may affect the refund posture of those entries. Review U.S. note 2(j) to subchapter III of Chapter 99 in the HTS for the criteria that governed each exemption heading.

Rate windows and effective dates

The heading operated across two distinct rate windows, both grounded in EO 14193 as amended by EO 14325:

The 35 percent rate was the rate in effect at the heading's end. No rate applied after 2026-02-23. Any entry filed after that date should not carry 9903.01.10; if it does, that is a classification error requiring correction.

These additional duties stacked on top of the column 1 general rate applicable to the underlying Chapter 1-97 HTS classification of the imported merchandise. They did not replace it. Other additional duties, such as any Section 232 or Section 301 duties applicable to the same goods, would also have continued to stack independently. Confirm the full duty stack for any affected entry against each program's own rules.

How the heading appeared on an entry alongside companion exemptions

Chapter 99 additional-duty headings like 9903.01.10 were reported as a second HTS line on CBP Form 7501, riding alongside the primary Chapter 1-97 classification line. The Chapter 1-97 line carried the substantive product description and the base duty rate. The 9903.01.10 line carried the IEEPA additional duty percentage and reported the dutiable value a second time to generate the extra duty amount.

Entries that used an exemption heading (9903.01.11 through 9903.01.15) instead would have reported that exemption heading on the second line, with zero additional duty. If your ACE data shows 9903.01.10 on an entry, that entry paid the additional duty at the rate corresponding to its entry date. For guidance on reading your ACE entry data, see the article on the ACE Portal application and importer account setup.

For context on how other ended IEEPA Chapter 99 headings worked in the same structural way, see the article on 9903.01.84 (Ended): IEEPA India 25% Tariff Heading Explained.

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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