IEEPA Tariff Codes: Which HTS Codes Were Affected and What You Can Reclaim

Understanding HTS Codes in the IEEPA Context

The Harmonized Tariff Schedule (HTS) is the classification system the United States uses to categorize every imported product and determine applicable duty rates. HTS codes are 10-digit numbers organized hierarchically: the first 2 digits identify a broad chapter, the next 4 digits a heading, and additional digits specify subheadings down to the specific product level.

When IEEPA reciprocal tariffs were imposed in 2025, they applied as an “ad valorem” (percentage of value) rate on top of existing HTS-based duty rates. The IEEPA rate was a country-specific overlay — it did not create new HTS codes, but rather added a surcharge across most HTS chapters for goods originating from designated countries.

Which HTS Chapters Were Subject to IEEPA Rates?

The IEEPA reciprocal tariff structure applied broadly across nearly all merchandise chapters (Chapters 1–97 of the HTS). However, certain categories were explicitly excluded or had pre-existing carve-outs:

HTS Chapter Range	Category	IEEPA Status
01–24	Agricultural and food products	Generally included; some USMCA-exempt goods excluded
25–27	Minerals, fuels, ores	Included (energy products often had 10% baseline)
28–38	Chemicals, pharmaceuticals	Included
39–40	Plastics and rubber	Included
41–43	Leather goods	Included
44–46	Wood and paper products	Included
47–49	Pulp, paper	Included
50–63	Textiles and apparel	Included; major refund opportunity
64–67	Footwear, headgear	Included
68–70	Stone, glass, ceramics	Included
71	Precious metals, jewelry	Included
72–83	Base metals and articles	Included; note Section 232 steel/aluminum separate
84–85	Machinery and electronics	Included; largest refund opportunity by dollar volume
86–89	Transport equipment	Included; autos/parts separate 25% rate may apply
90–92	Optical, medical instruments	Included
93	Arms and ammunition	Excluded
94–96	Furniture, toys, miscellaneous	Included
97	Art, collectibles	Included

Key Product Categories by HTS Chapter

Electronics (Chapters 84–85)

This is where the single largest refund opportunity exists by dollar value. Chapter 84 covers machinery, computers, and mechanical appliances. Chapter 85 covers electrical equipment, semiconductors, and consumer electronics. Companies importing laptops, smartphones, circuit boards, HVAC equipment, industrial machinery, and LED lighting typically have substantial IEEPA duty exposure.

Representative HTS codes in this space:

• 8471.30 (portable automatic data processing machines — laptops)
• 8517.12 (smartphones and cellular devices)
• 8542.31–39 (integrated circuits and semiconductors)
• 8450.11–20 (washing machines)
• 8414.51 (table and ceiling fans)

Textiles and Apparel (Chapters 50–63)

The second-largest category by volume. The combination of high IEEPA rates on major apparel-producing countries (Vietnam at 46%, Bangladesh at 37%) with large import volumes creates substantial refund exposure for retailers, brands, and distributors.

Representative HTS codes:

• 6109.10 (t-shirts, cotton)
• 6203.42 (men’s trousers, cotton)
• 6204.62 (women’s trousers, cotton)
• 6110.20 (sweaters, cotton)
• 6307.90 (other made-up textile articles)

Furniture and Home Goods (Chapter 94)

A major refund category, particularly for goods from China and Vietnam. Chapter 94 covers furniture, mattresses, lamps, and prefabricated buildings.

Representative HTS codes:

• 9401.61–69 (upholstered seats/sofas)
• 9403.20–90 (metal and wooden furniture)
• 9404.21–29 (mattresses)
• 9405.11–99 (lamps and lighting equipment)

Toys and Games (Chapter 95)

Chapter 95 covers dolls, action figures, video game consoles, board games, and outdoor play equipment. Much of this category sources from China (34% IEEPA rate) and Vietnam (46%).

Auto Parts (Chapters 87, 84, 73)

Auto parts can fall under multiple HTS chapters. While complete passenger vehicles may have faced additional tariffs under Section 232, many individual components imported under Chapter 87 (and engine/mechanical parts under Chapter 84) were subject to IEEPA rates.

How to Cross-Reference Your Entries

To determine which of your entries are potentially refundable:

1. Obtain all CBP Form 7501s for entries cleared between your country’s IEEPA effective date and February 20, 2026.

2. Check the “Country of Origin” field on each entry. The country of origin — not the country of export or the port of loading — determines which IEEPA rate applied.

3. Identify the HTS codes on each entry line. Confirm those codes fall within refundable chapters (avoid any Sec. 232 steel/aluminum codes for those tariff lines).

4. Look at the duty column on the 7501. If IEEPA duties were assessed, you’ll see them listed separately or as part of the total duties collected. Some CBP systems labeled these with specific collection codes for IEEPA.

5. Aggregate by entry. The CAPE CSV requires data at the individual entry line level, so you’ll need both your entry summary numbers and the per-line breakdown.

Section 232 Steel and Aluminum: A Common Source of Confusion

Many importers of steel, aluminum, and downstream metal products are confused about which duties are refundable. The short answer: IEEPA duties on metal products are refundable, but Section 232 steel and aluminum tariffs are not.

Section 232 tariffs were separately assessed (typically 25% on steel, 10% on aluminum, with country-specific variations) and should appear as distinct line items on your 7501. An importer of Chinese steel products may have paid both Section 232 and IEEPA duties — only the IEEPA portion is refundable.

Working with Your Customs Broker

Your licensed customs broker should be able to pull entry summaries from their ACE records and help you identify which entries contained IEEPA duties. Most brokers who handled imports during 2025 have this data readily available. If you self-filed through ACE, you can access your entry history directly through the CBP portal.