China Tariff Refunds: Navigating IEEPA Chapter 99 Duties on Chinese Imports

Status as of October 2026. CBP refunds IEEPA duties through the CAPE program in ACE, not through individual paper claims. CAPE Phase 1 opened April 20, 2026 for unliquidated entries and entries recently liquidated; since June 29, 2026 it also accepts entries flagged for reconciliation when the reconciliation entry has not been filed. An entry that liquidated too long ago for CAPE to take it needs a protest within 180 days of liquidation under 19 U.S.C. § 1514, and an entry whose protest window has closed is final. Duties on Chinese goods under Section 301, Section 232, and the Section 301 forced labor action in force since July 24, 2026 were not affected by the ruling and are not refundable through CAPE. See the CAPE error reference and the FAQ for the current mechanics.

China tariff refunds are the single largest category of IEEPA duty recovery claims following the Supreme Court's February 2026 ruling. Chinese imports faced the most complex and punitive layering of chapter 99 surcharges (including fentanyl-related duties, Liberation Day tariffs, and the global baseline rate), making an experienced IEEPA refund consultant essential for any importer looking to navigate the recovery landscape and maximize the value of their claims.

The cape refund process for Chinese goods requires careful parsing of multiple overlapping duty codes. Importers should start by pulling the es 003 report from ACE to identify every entry summary that carried an IEEPA surcharge on China-origin merchandise. Because China was subject to more chapter 99 subheadings than any other country, the potential refund amounts are correspondingly larger, and the filing complexity is higher.

Which Chapter 99 Codes Apply to Chinese Imports?

China was targeted by several distinct IEEPA tariff actions, each creating its own set of duty-bearing and exclusion codes:

• 9903.01.25: the global reciprocal baseline rate of +10%, applied to products of all countries including China, effective April 5, 2025
• 9903.01.20: a China-specific fentanyl-related surcharge of +10% ad valorem, effective February 4, 2025, imposed under the executive order addressing the flow of fentanyl precursors
• 9903.01.24: a fentanyl escalation rate originally set at +20%, later reduced to +10% effective November 10, 2025, covering additional Chinese articles as the fentanyl tariff program expanded
• 9903.01.63: the Liberation Day tariff of +34% on Chinese goods, announced April 2, 2025; this rate was briefly escalated to +84% on April 9 and then +125% on April 10 before being suspended on May 14, 2025 following trade negotiations

At peak enforcement, the stacking of 9903.01.25, 9903.01.20, and 9903.01.63 meant some Chinese imports faced combined IEEPA surcharges exceeding 145% on top of existing MFN duties, Section 301 tariffs, and any applicable antidumping or countervailing duty orders.

What Chinese Products Were Most Affected?

China is the largest source of U.S. imports by value, and the IEEPA tariffs touched virtually every product category. The following sectors experienced the greatest cost impact:

• Steel and aluminum products: Chinese steel imports already subject to Section 232 duties were carved out of some IEEPA codes to avoid double-counting, but many intermediate steel products, steel-containing manufactured goods, and specialty alloys still carried the full IEEPA surcharge
• Computer and electronic goods: laptops, servers, networking equipment, printed circuit boards, and semiconductor-related components faced the stacked rates, driving significant cost increases for U.S. technology companies and resellers
• Consumer goods: furniture, toys, housewares, lighting fixtures, and small appliances from China bore the full weight of the tariff layers, with landed cost increases that rippled through retail pricing
• Apparel and textiles: Chinese-origin garments, fabrics, and textile inputs faced the combined surcharges on top of already elevated MFN duty rates, compounding the cost burden for fashion and textile importers
• Advanced manufacturing inputs: industrial machinery, electric motors, lithium-ion batteries, solar panels, and EV components from China were subject to IEEPA rates that stacked with existing Section 301 tariffs, creating effective duty rates that in some cases exceeded 200%
• Polymers, coatings, and chemical products: Chinese-origin resins, adhesives, paints, and specialty chemicals used across U.S. manufacturing faced the IEEPA surcharges, increasing input costs for downstream producers

Are There Exclusions for Chinese Goods?

Yes, though fewer than for some other countries given the breadth of the China-specific tariff actions. The primary exclusion codes include:

• 9903.01.21: humanitarian donations such as food, clothing, and medicine intended to relieve human suffering, exempt from the fentanyl-related surcharge
• 9903.01.22: informational materials including publications, films, photographs, tapes, compact discs, and artworks of Chinese origin
• 9903.01.23: goods loaded onto a vessel and in transit before February 1, 2025 and entered before March 7, 2025, exempt from the initial fentanyl tariff under 9903.01.20

Importers should note that the Liberation Day tariff (9903.01.63) had its own suspension effective May 14, 2025, meaning entries made after that date should not carry the +34% rate. Any entries incorrectly assessed the Liberation Day surcharge after the suspension date represent an additional refund opportunity.

How Does the Refund Process Work for Chinese Imports?

The volume and complexity of China-origin IEEPA claims make structured preparation critical:

• Pull your ES 003 report: this ACE report surfaces every entry summary with chapter 99 duty lines; for China importers, expect a high volume of results given the multiple overlapping codes
• Map each entry to the correct codes: determine which combination of 9903.01.25, 9903.01.20, 9903.01.24, and 9903.01.63 was assessed, and whether the rates matched the effective dates (particularly important for the fluctuating Liberation Day rates)
• Check for exclusions and suspension errors: verify whether any humanitarian, informational, or in-transit exclusions (9903.01.21–23) should have applied but were missed, and whether entries after May 14, 2025 were incorrectly assessed the 9903.01.63 surcharge
• Calculate the refund amount: for each entry, the refundable amount equals all IEEPA-attributable duties paid, including merchandise processing fees calculated on the inflated dutiable value
• File the claim: submit the entries in a CAPE Declaration in the ACE portal, or have your broker do it; for entries CAPE will not take because they liquidated too long ago, file a protest within 180 days of liquidation. Keep the entry summaries, commercial invoices, and country-of-origin certificates ready in case CBP asks for them
• Account for Section 301 interaction: ensure that your refund calculations separate IEEPA duties from Section 301 tariffs, which remain valid and are not subject to the Supreme Court ruling

What Deadlines Should Chinese Import Claimants Watch?

• Unliquidated entries: include them in a CAPE Declaration; CBP then liquidates them without the IEEPA duty
• Liquidated entries: CAPE takes entries liquidated within the preceding 80 days; for an older liquidation you have 180 days from the date of liquidation to file a protest under 19 USC 1514, and after that the entry is final
• High-volume filers: importers with hundreds or thousands of affected entries should consider batch processing through an automated system to avoid missing protest deadlines on individual entries

Given that China accounted for the highest IEEPA tariff rates and the largest share of affected import value, Chinese import refunds represent the most significant recovery opportunity for U.S. importers. Companies that imported electronics, consumer goods, or industrial inputs from China during the tariff period should treat IEEPA recovery as a high-priority financial initiative.