9903.01.23 (Ended): IEEPA China Fentanyl Exemption Heading Explained

Key Points

• Heading 9903.01.23 ended on February 24, 2026, and is no longer in force as of October 2026.
• It was an exemption-type heading in the China Fentanyl program, so it carried no additional duty itself: the rate was 0 percent from February 4, 2025 through March 6, 2025.
• It covered goods of China and Hong Kong that were loaded before 12:01 a.m. eastern standard time on February 1, 2025 and entered or withdrawn from warehouse for consumption from February 4, 2025 up to, but not including, 12:01 a.m. eastern standard time on March 7, 2025.
• Because the heading carried no duty, its end created nothing to refund under it.
• If IEEPA duty was deposited under a companion duty heading because this heading was not claimed, that deposit can be sought through CBP's CAPE process in ACE.

On this page

1. What 9903.01.23 was
2. Affected products and HTS coverage
3. Rate and effective window
4. How it appeared on an entry and sat beside other headings
5. What importers should do
6. Key references

HTS 9903.01.23 was a Chapter 99 exemption heading in the IEEPA China Fentanyl program. It let qualifying goods of China and Hong Kong that were already on the water enter at no additional duty during a short window. The heading ended on February 24, 2026, and it is not in force as of October 2026.

The links in this article go to the primary documents: the proclamations, Federal Register notices, and official tariff schedule pages themselves. Read the source.

What 9903.01.23 was

The heading belonged to the China Fentanyl program, which rested on EO 14195, as amended by EO 14228. Orders of this kind are published on the White House presidential actions page and in the Federal Register.

The key point is what the heading was not. It was not a duty line. It was an exception or claim heading inside the program. Filers used it to show that a shipment fell inside a relief window, so the shipment did not take the program's additional duty.

Affected products and HTS coverage

The official heading text described the covered goods this way: articles the product of China and Hong Kong that met two timing conditions.

• They were loaded onto a vessel at the port of loading, or were in transit on the final mode of transport before entry into the United States, before 12:01 a.m. eastern standard time on February 1, 2025.
• They were entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern standard time on February 4, 2025, and before 12:01 a.m. eastern standard time on March 7, 2025.

Carve-outs in the heading text

The heading did not apply to products described in headings 9903.01.21 and 9903.01.22. Those products were handled under their own headings. It also did not apply to products for personal use included in accompanied baggage of persons arriving in the United States. To see what the neighboring headings covered, check the current HTSUS or ask your broker. This article does not describe them beyond the reference in the heading text.

Rate and effective window

The rate under 9903.01.23 was no additional duty. The rate window ran at 0 percent from February 4, 2025 through March 6, 2025. That matches the heading text, which stopped at 12:01 a.m. eastern standard time on March 7, 2025. The heading's effective date was February 4, 2025, and it ended on February 24, 2026.

Ordinary duties were a separate matter. Normal column 1 duty on the chapter 1 to 97 line was not affected by this heading. Confirm the treatment of any specific entry in the current HTSUS.

How it appeared on an entry and sat beside other headings

A Chapter 99 heading is reported alongside the regular chapter 1 to 97 line, not in place of it. A qualifying entry line carried its normal tariff classification plus 9903.01.23 to show the exemption was claimed. The line then carried no additional program duty.

The heading sat beside two other exemption headings, 9903.01.21 and 9903.01.22, which the heading text itself excluded from its scope. The three together mattered when reviewing a China or Hong Kong entry from the window. Goods described in 9903.01.21 or 9903.01.22 belonged under those headings, and 9903.01.23 picked up the rest of the qualifying in-transit goods.

The same pattern of a no-duty claim heading that later ended shows up in other programs. See the explainers on 9903.01.87 and 9903.01.26. For a wider view of the year's headings, see the 2026 tariff code overview.

What importers should do

Because 9903.01.23 carried no duty, its end on February 24, 2026 created no refund under this heading, and nothing here promises one. The practical question is whether an entry in the window paid IEEPA duty anyway.

• Pull the entries. Identify China and Hong Kong entries from the February 4, 2025 through March 6, 2025 window. Check whether 9903.01.23 was claimed on the 7501 lines.
• Look for a companion deposit. If IEEPA duty was deposited under a companion duty heading because this heading was not claimed, that deposit can be sought through CBP's CAPE process in ACE.
• Gather what CAPE needs. Have the entry numbers, the 7501 lines that carried the deposit, and the liquidation status of each entry ready before you start.
• Follow the steps and check rejections. The filing steps are in the IEEPA tariff refund guide. Common rejections are on the CAPE errors page.

Key references

• White House presidential actions: the home for the executive orders behind the program, EO 14195 and EO 14228.
• Federal Register: search here for the published text of the orders.
• Harmonized Tariff Schedule: the official Chapter 99 pages, including headings 9903.01.21, 9903.01.22 and 9903.01.23.
• U.S. Customs and Border Protection: guidance and CSMS messages on IEEPA headings and CAPE.
• IEEPA tariff refund guide: the CAPE steps for seeking IEEPA deposits.
• CAPE errors: common rejections and what they mean.