Will CAPE refund my Section 301 China duties?

No. Section 301 duties were imposed under the Trade Act of 1974 and were not affected by the Supreme Court's IEEPA ruling. They remain owed and CAPE Phase 1 will not refund them. Your refund target is only the IEEPA Chapter 99 line, which appears separately on your CBP-7501 entry summary.

Will CAPE refund my Section 232 steel or aluminum duties?

No. Section 232 duties were imposed under the Trade Expansion Act of 1962 and were not affected by the Supreme Court's IEEPA ruling. Like Section 301, they remain owed. CAPE refunds only the IEEPA layer of the duty stack.

How do I separate the IEEPA portion from Section 301 and 232 on my entry summary?

Each statutory regime appears as a distinct Chapter 99 line on the CBP-7501. IEEPA lines fall within 9903.01.25 – 9903.01.70. Section 301 lines fall within different sub-ranges (typically 9903.88.xx for List 1–4 and 9903.91.xx for tranche-specific items). Section 232 steel and aluminum lines fall within 9903.80.xx and 9903.85.xx ranges. Sum only the IEEPA line for your CAPE refund estimate.

What happens to my refund estimate if I include Section 301 by mistake?

Your estimate will be inflated by 7.5% to 25% of the affected merchandise value, depending on the Section 301 list. CBP will refund only the IEEPA amount, so the actual deposit will fall short of your estimate. This is one of the most common reasons importers report 'refund less than expected' issues. See our guide on why your IEEPA refund may not match your estimate.

Are there any duty regimes other than IEEPA, 301, and 232 that may stack on the same entry?

Yes. Common additional layers include AD/CVD (antidumping / countervailing duties), Section 201 safeguard duties (washing machines, solar cells in certain windows), and merchandise processing fees (MPF). Each is governed by separate statutes and remains owed regardless of the IEEPA refund. CAPE Phase 1 refunds only the IEEPA layer.

IEEPA, Section 301, and Section 232 Stacking: What CAPE Actually Refunds

The most common refund-estimation mistake is not a math error. It is including the wrong duty layers in the calculation.

If your entries paid IEEPA, Section 301, and Section 232 duties on the same line, only one of those three is coming back through CAPE Phase 1.

The Four Common Layers in the Stack

A typical Chinese-origin steel-content entry between February 2025 and February 2026 might have looked like this on the CBP-7501:

Layer	Statute	Typical Rate	Chapter 99 Range	CAPE-Refundable?
Underlying HTS classification	HTSUS Chapter 1–97	Varies (often 0% – 5%)	n/a (main HTS line)	No
Section 301 China duty	Trade Act of 1974 § 301	7.5% – 25% (List 1–4)	9903.88.xx, 9903.91.xx	No
Section 232 steel/aluminum	Trade Expansion Act § 232	25% (steel), 10% (aluminum)	9903.80.xx, 9903.85.xx	No
IEEPA “fentanyl” surcharge	IEEPA (EO 14195)	20%	9903.01.25 – 9903.01.70	Yes

Only the bottom row comes back through CAPE Phase 1.

Why CAPE Doesn’t Touch Sections 301 and 232

The Supreme Court’s February 2026 ruling in Learning Resources, Inc. v. Trump held that IEEPA does not authorize the President to impose tariffs. That ruling is narrow — it speaks only to IEEPA-based tariffs.

Section 301 duties were imposed under the Trade Act of 1974, a different statute that explicitly authorizes the President (acting through USTR) to impose tariffs in response to unfair foreign trade practices. Section 232 duties were imposed under the Trade Expansion Act of 1962, which authorizes tariffs in response to national-security-implicating imports. Neither statute was challenged in Learning Resources. Both remain in effect.

So the duty stack on a Chinese-origin entry is partly refundable (the IEEPA layer) and partly not (Sections 301 and 232 layers). The same is true for any entry where IEEPA layered on top of pre-existing trade-remedy duties.

How to Isolate the IEEPA Portion

Step 1 — Pull the CBP-7501 entry summary. Each Chapter 99 line is a separate row with its own duty calculation. The line includes the HTS code, the value covered, the rate, and the duty paid.

Step 2 — Find the Chapter 99 lines in the IEEPA range. Look for lines with HTS codes between 9903.01.25 and 9903.01.70. That is the umbrella IEEPA range that CBP confirmed in its CAPE Error Dictionary (CSMS #68401616).

Step 3 — Sum the duty paid on those lines only. The dollar amount on the IEEPA Chapter 99 line is your refund target for that entry. Do not include the underlying HTS line, the Section 301 line, the Section 232 line, AD/CVD lines, or MPF.

Step 4 — Repeat per entry. Each entry has its own stack. The IEEPA portion as a percentage of total entry duty varies a lot — high for entries with low underlying duty (USMCA-preferred), low for entries with heavy Section 301 + 232 layering.

Why Importers Get This Wrong

Whole-entry estimation. Many importers estimate refunds as “20% of merchandise value” for Chinese entries. That double-counts everything except the IEEPA line. The right number is typically much lower than 20% of merchandise value, because the IEEPA line itself was 20% of only the value reported on that line — which may not be the full merchandise value if the line covered only a portion of the shipment.

Spreadsheet inheritance. Spreadsheets built by brokers or duty management software for tracking total tariff exposure often roll up all Chapter 99 layers into a single “tariff” column. That number is fine for cost accounting but wrong for CAPE refund estimation.

Section 301 confusion with IEEPA on China. The IEEPA “fentanyl” tariff and the Section 301 “China trade” tariff are both targeted at Chinese imports. They are easy to conflate. They are statutorily separate. CAPE refunds one and not the other.

Section 232 on derivative products. Section 232 expanded over the years to cover derivative products that contain steel or aluminum, not just raw steel and aluminum. Many entries contain a Section 232 line for the steel-content portion of a finished product. That line is not refundable.

The Quick Mental Test

If a CFO asks “what fraction of our tariff bill is coming back?” the answer for a Chinese-origin importer is almost never “all of it” — it is “only the IEEPA layer.” For a Canadian-origin importer with USMCA preferences, the IEEPA layer might be 90%+ of the duty paid (because the underlying classification was zero). For a Chinese steel importer with Section 301 + Section 232 + AD/CVD on top of IEEPA, the IEEPA layer might be 25% of the duty paid.

The IEEPA share depends entirely on what other layers were on the entry. Calculate per entry, not as a portfolio average.

Common Mistakes

Mistake — Estimating refund as 20% (or 25%) of merchandise value. This is wrong for almost every entry. The correct estimate is the dollar amount actually paid on the IEEPA Chapter 99 line.

Mistake — Treating “tariff refund” as one bucket internally. Finance teams need to know which duty layers are coming back and which are not. Build the IEEPA isolation into your refund tracker from day one.

Mistake — Promising customers refund pass-through without checking the stack. Some importers committed to passing tariff refunds through to customers. Make sure your “refund” number reflects only the CAPE-recoverable IEEPA portion, not the full Section 301 + 232 stack.

Mistake — Filing CAPE without verifying the IEEPA line is actually present. A Chinese-origin entry without an IEEPA Chapter 99 line is not CAPE-eligible. CSMS #68401616 (Error 12) explicitly rejects “NO IEEPA HTS ON ENTRY.” Do not assume — inspect.

Where This Connects

For per-country breakdowns of the IEEPA layer, see Recover IEEPA Tariffs by Country of Origin. For the broader filing process, see the 7-step CAPE filing guide. For the case where your refund deposit falls short of your estimate, see why your IEEPA refund may not match your estimate.

If you want a per-entry refund estimate that isolates only the IEEPA layer, request a free assessment.

CAPE Portal Guide is not a law firm, customs broker, or government agency. Duty-stack analysis on entries with multiple statutory regimes can be complex; consult a licensed customs attorney or broker for entry-level decisions.