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9903.02.78 (Ended): IEEPA Replacement Rates Exemption Heading

Published: October 24, 2026  ·  5 min read
9903.02.78 (Ended): IEEPA Replacement Rates Exemption Heading
Photo: RDNE Stock project / Pexels

Key Points

On this page

  1. What 9903.02.78 was
  2. Rate and effective window
  3. Scope and how it appeared on an entry
  4. Interaction with other IEEPA headings
  5. What importers should do
  6. Key references

9903.02.78 was a Chapter 99 heading in the IEEPA Replacement Rates program, and it ended on February 24, 2026. It was an exemption heading, not a duty heading: it applied no additional duty, and importers who claimed it paid 0 percent under it from August 7, 2025 through February 23, 2026. As of October 2026, it is no longer in force.

The links in this article go to the primary documents: the proclamations, Federal Register notices, and official tariff schedule pages themselves. Read the source. The official heading text and its current status are on the Harmonized Tariff Schedule pages at the USITC.

What 9903.02.78 was

The official heading text read: "Articles the product of any country, as provided for in subdivision (v)(iii)(b) of U.S. note 2 to this subchapter." The program was Replacement Rates, and the legal authority was EO 14326. The executive order is a White House document; the presidential actions page is the place to find it.

The heading was an exemption, exception, or claim heading. It did not impose a tariff. Its job was to identify entries that fell within the carve-out described in subdivision (v)(iii)(b) of U.S. note 2 so that those entries were not charged the additional IEEPA duty. The facts available to us do not spell out what goods that subdivision reached, so confirm the exact language of U.S. note 2 in the HTSUS before relying on any reading of it.

Rate and effective window

The zero rate never changed during that window. The only event in the heading's history after it took effect was its termination.

Scope and how it appeared on an entry

The heading text said "the product of any country," so it was not tied to a single origin. What mattered was whether the goods met the conditions in subdivision (v)(iii)(b) of U.S. note 2, not where they came from.

On an entry summary (CBP Form 7501), a Chapter 99 heading like this one was reported as its own line alongside the regular chapter 1 to 97 tariff line for the same goods. The regular line carried the ordinary classification and duty. The 9903.02.78 line signaled the exemption claim and showed no additional IEEPA duty. If the claim was left off, the goods were reported under a companion duty heading in the same program instead, and the IEEPA duty was deposited there.

Interaction with other IEEPA headings

9903.02.78 sat in the Replacement Rates program next to the program's duty headings, which is why it mattered as a claim heading. Claiming it kept an entry out of the duty headings; not claiming it could leave the entry in one. Other ended IEEPA exemption headings worked in a similar way, and we have covered some of them:

Those are separate headings with their own facts. Do not carry their scope or dates over to 9903.02.78. For how the 2026 Chapter 99 codes fit together, see the 2026 tariff code overview.

What importers should do

The refund position is narrow. This heading carried no duty of its own, so its end created nothing to refund under it, and nothing here promises a refund. The refund question arises only for entries that deposited IEEPA duty under a companion duty heading because this heading was not claimed. Those deposits can be pursued through CBP's CAPE process in ACE.

  1. Pull the affected entries. Identify entries from the August 7, 2025 to February 23, 2026 window where the goods fit the 9903.02.78 carve-out but IEEPA duty was deposited under a companion duty heading.
  2. Gather the entry details. Collect the entry numbers, the 7501 lines showing the duty heading that was reported, and the liquidation status of each entry.
  3. File through CAPE in ACE. The steps are on the IEEPA tariff refund guide, and the common rejections are on the CAPE errors page.
  4. Check the schedule. Confirm the current status of the heading and U.S. note 2 in the HTSUS, or with your broker, before you build a claim.

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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