Not everything you've paid in duties is eligible for an IEEPA refund. This is the mistake that trips up importers who see a big number on their entry summaries and assume most of it is recoverable. Some of those duties are from programs that have nothing to do with IEEPA — and filing for a refund on the wrong program wastes time and gets claims rejected.
Section 232 Duties
Section 232 tariffs were imposed on steel and aluminum imports under national security authority. The rates are 25% on steel and 10% on aluminum (with variations for certain countries and product categories). Section 232 also includes derivative tariffs that apply to downstream products containing steel or aluminum — but only if those products are classified under HTS codes within the scope of the 232 order.
Section 232 duties are not refundable through the IEEPA/CAPE process. They have their own legal basis, their own rate structure, and their own (limited) exclusion mechanisms. If your entry shows a Chapter 99 code in the 9903.80.xx range, that's Section 232.
Section 301 Duties
Section 301 tariffs target goods from China and are applied at rates of 7.5% or 25% depending on which list the HTS code falls under. These were imposed over multiple rounds (Lists 1 through 4A/4B) and cover thousands of product codes.
Section 301 duties are not part of the IEEPA program and are not refundable through CAPE. There have been some Section 301 exclusion processes in the past, but those are separate, have their own application procedures, and most have expired. Don't confuse 301 exclusions with IEEPA refunds — they are completely different.
Section 301 codes appear in the 9903.88.xx range.
Antidumping and Countervailing Duties (AD/CVD)
AD/CVD duties are assessed on specific products from specific countries where the Department of Commerce has determined that goods are being sold below fair value (dumping) or are benefiting from government subsidies (countervailing). These duties can be substantial — sometimes exceeding 200%.
AD/CVD duties have their own review process, their own administrative procedures, and their own annual rate adjustment mechanism. They are not IEEPA, they are not refundable through CAPE, and they should never be confused with reciprocal tariffs.
Section 122 Duties
Section 122 of the Trade Act gives the president authority to impose temporary import surcharges to address balance-of-payments deficits. These are rare but occasionally invoked. If your entries include Section 122 duties, those are governed by a different authority and a different process.
Base MFN Duties
Your base Most Favored Nation duty rate — the rate listed under "General" in the HTSUS for each classification — is not refundable through any special tariff program. If your product has a 3.5% base duty rate, that rate is what it is. IEEPA refunds only apply to the additional IEEPA tariff layer on top of the base rate.
How to Tell What's What
The Chapter 99 code on your 7501 tells you which program applied. Each program has its own code range. If you can read the Chapter 99 codes, you can identify which duties are IEEPA and which are something else.
This is exactly what the IEEPA Refund Screener does automatically — it reads your Chapter 99 codes, maps them to the correct tariff program, and only flags the lines where the duty was genuinely IEEPA. No false positives. No claiming 232 duties as IEEPA. No rejected filings.
If you're not sure what you're looking at, that's a good reason to either use the screener tool or have a broker review your entries before you file anything.