IEEPA HTS Codes: Chapter 99 Guide for CAPE Refund Filing
Every IEEPA duty on your entry summaries is identified by a specific HTS Chapter 99 code. Finding those codes is how you know what you are owed. Incorrect or missing Chapter 99 codes are among the top reasons CBP rejects CAPE Declarations. TariffIQ™ validates every code before submission.
The Supreme Court’s February 20, 2026 ruling in Learning Resources v. Trump held IEEPA tariffs unlawful, opening $166 billion in refunds for 330,000 importers of record. As of June 29, 2026, $71.06 billion has been certified and sent to Treasury through CBP’s CAPE system.
Following the Learning Resources v. Trump ruling that opened $166 billion in refunds for 330,000 importers, the Harmonized Tariff Schedule of the United States (HTSUS) Chapter 99 contains temporary and emergency duty provisions. IEEPA tariffs imposed during 2025 were encoded on entry summaries under Chapter 99 subheadings in the 9903.01.xx and 9903.02.xx ranges, with further differentiation at the eight-digit level by country of origin. When CBP processes your CAPE Declaration, it removes these Chapter 99 IEEPA codes from your entry summary lines and recalculates the duties owed without them. The difference — the IEEPA duty amount, plus statutory interest — becomes your refund. If your entry summary does not have a qualifying Chapter 99 IEEPA HTS code, the entry will fail validation and be excluded from the refund. No code, no refund.
How to Find Your Codes
How to Identify IEEPA HTS Codes on Your Entry Summaries
Log into your ACE Secure Data Portal account. Run the Entry Summary Detail Report (ES-003) and export it to Excel. Filter the HTSUS column for entries beginning with 9903.01 or 9903.02. Every row with one of these codes on it represents an entry line item where you paid an IEEPA duty. The duty amount associated with each Chapter 99 line is your refund exposure for that entry line. Add up the duty amounts across all matching rows to get your gross refund exposure before interest. If you do not have direct ACE access, your licensed customs broker who filed your entry summaries can pull the same report on your behalf under their ACE filer account.
Coding Errors That Cause Rejections
Chapter 99 Coding Errors That Cause CBP to Reject Your Declaration
The most common HTS-related rejection causes: (1) Entry has no qualifying Chapter 99 code — if your broker did not include the IEEPA Chapter 99 code on the original entry summary, the entry may need a Post-Summary Correction (PSC) before it can be CAPE-eligible. Note: CBP has stated that PSCs cannot be used directly for IEEPA refunds — the entry-level coding issue must be resolved before CAPE filing. (2) Wrong Chapter 99 subheading for the country of origin — IEEPA Chapter 99 codes are country-specific at the eight-digit level; using a China-origin code on a Vietnam-origin entry will cause a validation failure. (3) Framework Agreement entries with combined duty reporting — entries from South Korea, the EU, Japan, and Switzerland under Framework Agreements sometimes had IEEPA and Column 1 duties combined on a single line at a 15% ceiling rate. These require special treatment and broker consultation before CAPE filing.
After July 7 Changes
Chapter 99 Code Changes After July 7, 2026
Effective July 7, 2026, per CSMS #69127837, CAPE no longer accepts warehouse entries (Types 21/22). The Chapter 99 IEEPA codes on those entry types are not eligible for the current CAPE phase. Warehouse withdrawals (Types 31, 32, 34, 38) remain eligible — and the Chapter 99 codes on withdrawal entries are the correct basis for the refund, since IEEPA duties on warehoused goods were collected at the time of withdrawal, not at the time of warehouse entry. If your CAPE Declaration includes warehouse entries submitted between April 20 and July 6, 2026, without corresponding withdrawal entries, those warehouse entry Chapter 99 codes will not generate a refund — you must file a new Declaration using the withdrawal entry numbers and their Chapter 99 codes.
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Important Note: HTS Chapter 99 IEEPA codes are country-specific at the eight-digit level. Your licensed customs broker, who has access to your original entry summaries in ACE, is the correct party to confirm which codes appear on your entries and whether your entries qualify for CAPE filing. TariffIQ™ screens codes at the advisory level — your broker confirms at the filing level.
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Informational only. Not legal, tax, or financial advice. The Tariff Bureau LLC is not a law firm, is not a licensed customs broker, and is not affiliated with CBP or any U.S. government agency. The IEEPA statute of limitations accrual date remains legally unsettled. Consult qualified trade counsel for your specific situation.