CustomsGenius
← All Publications
News

9903.02.20 (Ended): IEEPA EU Replacement Rate Floor, 15%

Published: October 17, 2026  ·  8 min read

Key Points

On this page

  1. What HTS 9903.02.20 was and when it ended
  2. Legal authority and program context
  3. Affected products and EU scope
  4. Rate, effective window, and exclusions
  5. How the heading appeared on an entry
  6. Interaction with other IEEPA headings
  7. What importers should do
  8. Key references

HTS 9903.02.20 was a Chapter 99 IEEPA Replacement Rate heading that imposed a 15 percent ad valorem floor on covered articles of the European Union. It applied to entries made on or after August 7, 2025 and ceased to apply after February 23, 2026, when the heading was terminated effective February 24, 2026. Importers and brokers who filed entries during that window and reported this heading should review those entries now for liquidation status and potential duty refunds through CBP's CAPE process.

The links in this article go to the primary documents: the official tariff schedule, CBP guidance pages, and government source materials themselves. Read the source.

What HTS 9903.02.20 was and when it ended

HTS 9903.02.20 was a temporary Chapter 99 classification heading established under the IEEPA Replacement Rates program. As of October 17, 2026 (the as-of date for this article's facts), the heading had been terminated and was no longer in force. Its last day of applicability was February 23, 2026; entries filed on or after February 24, 2026 could no longer carry this heading.

During its active window, the heading functioned as a duty floor mechanism. If a covered EU article carried a Column 1-General ad valorem rate below 15 percent, the heading replaced that lower rate with a flat 15 percent rate. If the normal rate was already 15 percent or higher, the heading had no additional bite, and importers should confirm the interaction with a broker or by reviewing the current Harmonized Tariff Schedule at hts.usitc.gov.

Legal authority and program context

The heading was created pursuant to Executive Order 14326, which established the IEEPA Replacement Rates program affecting articles of the European Union. The program used the International Emergency Economic Powers Act authority to set minimum tariff floors for EU goods in categories where existing Column 1-General rates fell below the program threshold.

For importers researching the broader IEEPA landscape, the related article on 9903.01.25 (Ended): IEEPA Global Reciprocal Baseline, 10% Rate covers a parallel baseline heading that also ran under IEEPA authority and has since ended.

Affected products and EU scope

The heading applied to articles the product of the European Union that met both of the following conditions:

Country of origin for EU goods had to be established in the normal manner. Only goods originating in the European Union, as defined for purposes of EO 14326, fell within scope. If country of origin was in question for any entry, confirm with a licensed broker or by checking CBP guidance at cbp.gov.

In-transit exclusion

The official heading text carved out goods that were loaded onto a vessel at the port of loading and in transit on the final mode of transit before 12:01 a.m. eastern daylight time on August 7, 2025, provided those goods were also entered for consumption or withdrawn from warehouse for consumption before 12:01 a.m. eastern daylight time on October 5, 2025. Both conditions had to be met for a shipment to qualify for this in-transit exclusion.

Rate, effective window, and exclusions

The rate

The duty rate under 9903.02.20 was 15.0 percent ad valorem, applied as a flat floor. It did not stack on top of the existing Column 1-General rate; it replaced it for covered goods whose normal rate fell below 15 percent.

The effective window

The heading was active from August 7, 2025 through February 23, 2026. Any entry with a release or entry date outside that window should not have carried this heading. If a broker filed this heading on entries outside that window, a post-entry correction may be warranted. Review entry records against the liquidation status for each affected line.

Product exclusions within the heading text

The heading's official text explicitly excluded products described in the following other Chapter 99 headings, which carried their own separate treatment:

In addition, goods provided for in headings 9903.01.34 and 9903.02.01 were also excepted from this heading's coverage. If a shipment's goods fell into any of those heading descriptions, 9903.02.20 did not apply to them, even if they were EU-origin and otherwise below the 15 percent threshold.

See the related articles on 9903.01.32 (Ended) and 9903.01.33 (Ended) for context on the exemption headings that sat alongside 9903.02.20.

How the heading appeared on an entry

Like all Chapter 99 IEEPA headings, 9903.02.20 rode as a secondary classification line on CBP Form 7501 alongside the underlying Chapter 1-97 classification. The Chapter 1-97 line carried the article description and the normal statistical quantity; the 9903.02.20 line carried the IEEPA rate and the dutiable value. Brokers reported both lines on the same entry for each affected line item.

Because the heading replaced rather than stacked the normal rate for sub-15-percent goods, the total duty calculation on the 7501 reflected 15 percent applied to the entered value for covered goods, not the Column 1-General rate plus 15 percent. Entries that instead stacked both rates may have overcollected duties, which is one scenario that supports a CAPE claim.

For a broader view of how Chapter 99 codes interact with the 2026 tariff schedule, see the 2026 tariff code overview.

Interaction with other IEEPA headings

The IEEPA Replacement Rates program for EU goods ran alongside a series of exemption and special-treatment headings. The exclusion language in 9903.02.20's official text made clear that goods already covered by headings 9903.01.30 through 9903.01.33, 9903.02.74 through 9903.02.78, 9903.01.34, and 9903.02.01 were not subject to the 15 percent floor under this heading. Those headings governed their own product sets and rates independently.

Importers who filed entries with multiple IEEPA Chapter 99 codes on the same 7501 should map each line item to the correct heading and verify that no line was claimed under both a Replacement Rate heading and an exemption heading simultaneously. A systematic review of ACE entry data can surface those conflicts. The article Is There a Tariff Calculator That Checks a Whole ACE File? describes tools for running that kind of bulk check.

What importers should do

Key references


Working through tariffs on real entries? Create an account, then see plans for the full toolkit.

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.

Request Beta Access

Get early access to CustomsGenius and start recovering IEEPA refunds faster.

Beta Pilot Ongoing