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9903.01.24 (Ended): China Fentanyl IEEPA Tariff Explained

Published: October 15, 2026  ·  6 min read
9903.01.24 (Ended): China Fentanyl IEEPA Tariff Explained
Photo: Markus Winkler / Pexels

Key Points

On this page

  1. What 9903.01.24 was and when it ended
  2. Legal authority and program background
  3. Affected goods and country scope
  4. Rate windows and effective dates
  5. How 9903.01.24 sat alongside other Chapter 99 headings
  6. Refund path for duties paid under this heading
  7. What importers should do
  8. Key references

HTS heading 9903.01.24 was a temporary Chapter 99 overlay code that added an ad valorem duty on most articles the product of China and Hong Kong under the China Fentanyl IEEPA program. The heading took effect on March 4, 2025 at a 20 percent rate, was reduced to 10 percent on November 10, 2025, and terminated on February 24, 2026. Importers and brokers who filed entries while the heading was active should verify liquidation status and assess whether a duty refund claim through CBP's CAPE process is appropriate.

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

What 9903.01.24 was and when it ended

Heading 9903.01.24 was an IEEPA-based Chapter 99 tariff code that appeared on import entries alongside the underlying Chapter 1 through 97 classification. It was part of the China Fentanyl program, which used the International Emergency Economic Powers Act authority to impose additional duties on goods originating in China and Hong Kong.

As of October 15, 2026, this heading is terminated. It ended on February 24, 2026. No entry dated on or after that date should carry 9903.01.24. Any entry that does should be reviewed for correction before liquidation.

Legal authority and program background

The China Fentanyl program was established under Executive Order 14195, subsequently amended by Executive Order 14228. Those orders invoked IEEPA to address the national emergency related to fentanyl trafficking linked to China and Hong Kong. The additional duties collected under this program were separate from, and stacked on top of, any Section 301 duties already applicable to the same merchandise.

The official text of the heading, as published in the Harmonized Tariff Schedule, read: "Except for products described in headings 9903.01.21, 9903.01.22, 9903.01.23, articles the product of China and Hong Kong, as provided for in U.S. note 2(u) to this subchapter."

Affected goods and country scope

9903.01.24 applied broadly to articles the product of China and Hong Kong, subject to U.S. note 2(u) to Subchapter III of Chapter 99. The heading's scope was intentionally wide: if an article was of Chinese or Hong Kong origin and was not described in one of the three carve-out headings listed below, it fell under 9903.01.24.

Excluded goods

Three sibling headings carved out specific product categories from 9903.01.24's coverage. Articles described in any of the following were not subject to this heading:

Whether a specific product fell within one of those exclusion headings was determined by U.S. note 2(u) and the published product descriptions for those codes. Confirm coverage in the current HTSUS or with a licensed broker if you are evaluating a historical entry.

Rate windows and effective dates

The additional duty rate under 9903.01.24 changed twice during its life. Every rate below comes directly from the facts block for this heading:

The heading then terminated on February 24, 2026. The correct rate to apply to a historical entry depended on the entry date relative to these windows. Brokers amending or protesting old entries should match each entry date to its window before calculating the duty differential.

For a broader view of Chapter 99 overlay codes that remained active into 2026, see the 2026 tariff code overview.

How 9903.01.24 sat alongside other Chapter 99 headings

Like all Chapter 99 overlay codes, 9903.01.24 did not replace the underlying commodity classification. A shipment of Chinese-origin goods was entered on its normal Chapter 1 through 97 HTS line, and 9903.01.24 was reported as a secondary line on CBP Form 7501 to trigger the additional duty calculation.

Critically, 9903.01.24 stacked on top of any existing Section 301 duties already applicable to the same merchandise. An importer of a product subject to a 25 percent Section 301 rate, for example, would have owed that 25 percent plus the applicable China Fentanyl additional rate for the relevant window. Section 301 codes such as those described in 9903.91.11 and 9903.91.06 remained independent obligations; the termination of 9903.01.24 had no effect on those.

The exclusion headings 9903.01.21, 9903.01.22, and 9903.01.23 also rode on separate 7501 lines for goods that qualified for one of those carve-outs instead.

Refund path for duties paid under this heading

Duties deposited under an IEEPA heading, including 9903.01.24, were refundable through CBP's CAPE process in ACE. CAPE (Customs Automated Protest and Entry) is the mechanism CBP uses to process refund claims tied to these overlay codes.

What you need to prepare a claim

To prepare a CAPE claim for duties paid under 9903.01.24, an importer needs:

The step-by-step process for filing a CAPE claim is documented on the IEEPA tariff refund guide. Common reasons CBP rejects CAPE submissions, and how to fix them, are listed on the CAPE errors page.

For additional context on the distinction between duty drawback and IEEPA refund mechanisms, see Duty Drawback Software vs Duty Refund Recovery Software.

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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