These three tariff programs get conflated constantly — by importers, by online calculators, and sometimes by customs brokers. But they are separate programs with different legal authorities, different triggers, different rates, and different refund mechanisms. If you mix them up, you'll either miss refunds you're owed or file claims that get rejected.
Section 232: National Security Tariffs
Section 232 tariffs were imposed under the Trade Expansion Act of 1962, which allows the president to adjust imports that threaten national security. The primary targets are steel and aluminum.
The key thing to understand about Section 232 is that it applies based on HTS classification, not material composition. A finished machine that contains aluminum components is not automatically subject to Section 232 aluminum tariffs.
The tariff applies if the product itself is classified under an HTS code that falls within the scope of the 232 order — typically Chapter 72 (iron and steel), Chapter 73 (articles of iron or steel), and Chapter 76 (aluminum and articles thereof), plus certain derivative products.
This is the single most common source of tariff misapplication I see. A broker sees aluminum on a commercial invoice, assumes Section 232 applies, and adds a 10% or 25% derivative tariff to an entry that should have been duty-free. On a $300,000 machine, that's a $30,000–$75,000 error — on a single entry.
Section 232 tariffs are identified by Chapter 99 codes in the 9903.80.xx range.
Section 301: Trade Practices Tariffs
Section 301 tariffs were imposed under the Trade Act of 1974, targeting goods from China in response to intellectual property and trade practices findings. The tariffs apply to specific HTS codes listed in various annexes, with rates of 7.5% or 25% depending on the list.
Section 301 tariffs apply only to goods with China as the country of origin. If your product comes from Germany, Vietnam, or any other country, Section 301 does not apply — regardless of the HTS code.
Section 301 tariffs are identified by Chapter 99 codes in the 9903.88.xx range.
IEEPA: Reciprocal Tariffs
IEEPA tariffs were imposed under the International Emergency Economic Powers Act, a broader emergency authority that allows the president to impose economic measures during a declared national emergency. The IEEPA reciprocal tariffs apply to imports from a wide range of countries at varying rates.
Unlike Section 232 (which targets specific product categories) or Section 301 (which targets a specific country), IEEPA tariffs are broader in scope. They can apply to virtually any product from any covered country, with rates that have changed multiple times through executive orders.
IEEPA tariffs are identified by Chapter 99 codes in the 9903.01.xx range (among others — the specific codes depend on the executive order).
Why the Distinction Matters for Refunds
Each program has its own refund mechanism. IEEPA refunds are filed through the CAPE portal. Section 232 and Section 301 refunds — if they exist — follow different procedures and different legal authorities.
If you file an IEEPA refund claim for a duty that was actually Section 232, your claim will be denied. You haven't just wasted time — you may have also missed the deadline to pursue the correct remedy.
The free IEEPA calculators online generally don't separate these programs. They look at your total duties paid and assume a percentage is IEEPA-refundable. That's a rough estimate at best and dangerously wrong at worst.
How They Stack
A single entry line can be subject to more than one of these programs simultaneously. An import from China classified under an HTS code covered by both Section 301 and IEEPA would owe the base duty, plus the 301 rate, plus the IEEPA rate. This is called duty stacking.
The stacking order matters because each program's rate is applied to the customs value independently — they don't compound on each other. But if one of the programs doesn't actually apply to that HTS code or country, the entire calculation is wrong.
Getting the stacking right requires knowing exactly which Chapter 99 codes apply to which HTS classification and which country of origin. This is not guesswork — it's a classification exercise.
The Bottom Line
If someone tells you "your IEEPA refund is $X" without first confirming that the duties in question are actually IEEPA (and not 232 or 301), they haven't done the analysis. A real refund screening starts by separating the programs — then calculating what's recoverable.