Section 232 and Section 301 Duties Are Still Owed Even After IEEPA Tariffs Ended
By the Trade Compliance Team at Singer Tariff Recovery
If you’re asking whether Section 232 and Section 301 duties are still owed after the IEEPA ruling, the key point is that these are separate tariff programs.
The end of IEEPA tariffs did not automatically eliminate duties imposed under Section 232 or Section 301.
For importers, that distinction matters because a customs entry can contain several different layers of duties. Recovering one layer does not mean every other duty charged on the same entry disappears.
An importer evaluating Section 232 and Section 301 duties needs to separate each tariff program before calculating what was paid, what remains part of the landed cost, and what could qualify for recovery.
The IEEPA refund applies to qualifying IEEPA duties.
It should not be treated as a refund of the entire duty stack.
For a CFO, controller, or import manager updating landed costs after an IEEPA recovery, that distinction needs to stay clear. The business still needs to identify the other duty programs attached to its imports and account for them separately.
What Are Section 232 and Section 301 Duties?
Section 232 and Section 301 tariffs operate under different legal authorities from
IEEPA tariffs.
That means the legal treatment of IEEPA duties does not automatically determine what happens to Section 232 or Section 301 duties.
Each program needs to be evaluated on its own.
Section 232 Tariffs: National Security Duties on Certain Products
Section 232 tariffs are duties imposed under Section 232 of the Trade Expansion Act of 1962.
They have been used for certain imported products, including categories involving steel, aluminum, and copper.
For an importer, the practical issue is whether the product and classification fall within an applicable Section 232 measure.
That analysis should begin with the actual HTSUS classification and Chapter 99 information associated with the entry.
Do not assume that every product containing steel, aluminum, or copper receives identical treatment.
Product coverage, classifications, applicable exclusions, and other entry-specific details can affect the analysis.
Section 301 Tariffs: Duties Connected to Trade Practices
Section 301 tariffs arise under the Trade Act of 1974 and impose additional duties on goods connected to specified trade practices.
Many U.S. importers are familiar with Section 301 because of the additional duties applied to numerous Chinese-origin products.
For a business importing from China, Section 301 can remain an important part of the landed cost even when the same entry also contains another tariff layer.
The rate and treatment depend on the product, origin, HTSUS classification, applicable Chapter 99 provisions, and any exclusion or other treatment available for the entry.
That is why you should separate Section 301 from IEEPA when reviewing historical customs data or building a current landed cost model.
How These Duties Differ From IEEPA Tariffs
The International Emergency Economic Powers Act imposed IEEPA tariffs.
They were legally distinct from Section 232 and Section 301 duties.
That distinction is central to tariff recovery.
An entry that contains a qualifying IEEPA duty can also contain other duties imposed under separate legal authority.
Recovering the IEEPA portion does not automatically convert those other charges into refundable duties.
For importers, break down the customs entry by duty type.
Identify the ordinary duty rate.
Identify any IEEPA duties.
Identify any Section 232 duties.
Identify any Section 301 duties.
Then determine the treatment that applies to each layer.
That is a much more reliable approach than looking at the total duties paid on an entry and assuming the entire amount belongs in an IEEPA refund calculation.
What Tariff Stacking Means for an Importer
Tariff stacking occurs when more than one tariff or additional duty program applies to the same imported merchandise.
A shipment can therefore have several duty components attached to a single entry.
For example, an entry could include an ordinary customs duty and one or more additional duties under separate tariff programs.
Those amounts need to be identified and calculated according to the classifications and rules that apply to that particular merchandise.
For an importer reviewing potential IEEPA recovery, tariff stacking creates an important accounting issue.
The total amount paid to CBP is not necessarily the amount potentially recoverable.
The business needs to separate the IEEPA layer from the other duties shown in the customs records.
That same separation matters after a refund.
If the company receives an IEEPA recovery, its landed cost model should reflect the refund of that specific duty component without automatically removing
Section 232, Section 301, or other charges that continue to apply to the merchandise.
The first step, therefore, is not to ask how much the company paid in tariffs overall.
It is identifying which tariff programs produced those payments.
Did the Supreme Court Ruling End Section 232 and Section 301 Duties?
No.
The Supreme Court’s February 20, 2026 ruling addressed tariffs imposed under IEEPA.
It did not automatically eliminate Section 232 duties imposed under the Trade Expansion Act of 1962 or Section 301 duties imposed under the Trade Act of 1974.
For importers, the distinction comes down to legal authority.
IEEPA, Section 232, and Section 301 are separate tariff authorities. A ruling addressing one does not automatically change the treatment of duties imposed under another.
That is why importers should not remove Section 232 or Section 301 duties from their landed cost calculations simply because qualifying IEEPA duties are being evaluated for recovery.
What the February 20, 2026 IEEPA Ruling Actually Decided
The Supreme Court concluded that IEEPA did not authorize the tariffs at issue in the case.
The ruling addressed IEEPA-based tariffs.
Section 232 and Section 301 duties were not the tariff programs being decided in that case.
That distinction matters when reviewing customs entries.
An importer can have an entry containing an IEEPA duty alongside a Section 232 or Section 301 duty.
Evaluate the IEEPA portion under the applicable refund process.
Evaluate the other duty layers separately under the legal authority and customs
treatment that apply to them.
For accounting purposes, do not group those amounts as a single tariff charge.
Why Section 232 and Section 301 Are Different
Section 232 and Section 301 come from different statutes and address different
trade issues.
Section 232 operates under the Trade Expansion Act of 1962 and addresses imports within its national security framework.
Section 301 operates under the Trade Act of 1974 and addresses certain foreign trade practices.
IEEPA operates under a separate emergency-powers statute.
That means the legal analysis that affected IEEPA tariffs does not automatically carry over to Section 232 or Section 301.
For an importer, the practical result is straightforward.
Do not determine whether a duty is still owed based only on when it was collected.
Determine which legal authority produced the duty.
You can usually trace that information through the HTSUS and Chapter 99 classifications associated with the entry.
What Happened After the IEEPA Ruling
The tariff environment continued to change after the IEEPA ruling.
For importers, those changes make it even more important to identify each duty by its legal authority rather than treating every additional tariff as part of one program.
Temporary or newly imposed tariff measures can have their own effective dates, country coverage, product coverage, classifications, and requirements.
At the same time, you need to evaluate existing Section 232 and Section 301 obligations separately.
This is especially important when a company updates landed costs or compares entries from different periods.
A shipment imported under one tariff structure should not automatically be used as the model for a shipment entered months later.
The entry date, country of origin, HTSUS classification, Chapter 99 classifications, and tariff programs in effect at the time all matter.
Tariff Stacking: When Section 232 and Section 301 Apply to the Same Shipment
A single customs entry can contain more than one additional duty program.
That is tariff stacking.
For example, merchandise can fall within a Section 232 product category while also being subject to an applicable Section 301 duty based on its country of
origin and classification.
When that happens, the importer needs to identify each applicable duty separately.
One additional tariff does not necessarily replace another.
How to Identify Whether Your Shipment Triggers Multiple Tariff Programs
Start with the product and the country of origin.
For Section 232, determine whether the merchandise and its classification fall within the scope of an applicable Section 232 measure.
For Section 301, determine whether the merchandise, origin, and classification fall within an applicable Section 301 measure.
Then look at the actual customs entry.
The Chapter 99 information can help show which additional duty programs were applied.
If more than one Chapter 99 classification appears, the entry can contain multiple additional duty layers that need to be analyzed separately.
Do not assume that a Chinese-origin product automatically carries every Section 301 duty.
Likewise, do not assume that every product containing steel, aluminum, or copper automatically receives the same Section 232 treatment.
The analysis depends on the merchandise and the classifications that apply to the specific entry.
Using HTSUS Chapter 99 to Calculate Cumulative Duty Obligations
HTSUS Chapter 99 is an important part of identifying additional duties on a customs entry.
An importer reviewing its duty stack should look beyond the ordinary HTSUS classification and identify the Chapter 99 provisions associated with the merchandise.
That review can show whether the entry contains Section 232, Section 301, IEEPA, or another additional duty component.
The amounts should then be separated.
For example, the entry can include:
the ordinary customs duty associated with the product classification
an applicable Section 232 additional duty
an applicable Section 301 additional duty
an IEEPA duty paid during the period when that program applied
The exact combination depends on the entry.
This separation matters most when the importer calculates potential IEEPA recovery.
Only the qualifying IEEPA component belongs in that specific refund analysis.
The other duty layers need to remain separate.
Common Stacking Scenario: Chinese-Origin Steel
Chinese-origin steel illustrates why entry-level review matters.
Depending on the product, classification, entry date, and applicable tariff provisions, a shipment can contain an ordinary customs duty, an applicable Section 232 duty, an applicable Section 301 duty, and, for an entry made during the relevant period, an IEEPA
duty.
Do not treat those charges as a single combined tariff for refund purposes.
The IEEPA portion is the layer that needs to be evaluated for IEEPA duty refund eligibility.
Section 232 and Section 301 amounts on the same entry need their own analysis.
This is where an ACE entry review becomes valuable.
Instead of asking, “How much did we pay in tariffs on this shipment?” the importer can identify:
What was the ordinary duty?
What was Section 232?
What was Section 301?
What was IEEPA?
Once those amounts are separated, the business has a much clearer picture of its potential
IEEPA recovery and the duty costs that must remain in its landed cost model.
What Section 232 and Section 301 Duties Are NOT Refundable Through the IEEPA Refund Process
The IEEPA refund process applies to qualifying IEEPA duties.
It does not turn Section 232 or Section 301 duties paid on the same customs entry into IEEPA refunds.
That distinction matters because one entry can contain several different duty layers.
An importer reviewing a potential refund must identify the IEEPA-specific amount rather than using total duties paid as the refund figure.
Section 232 and Section 301 amounts need to be analyzed separately under the rules that apply to those programs.
IEEPA Refunds Through CBP’s CAPE Program: Scope and Limits
The IEEPA refund eligibility framework focuses on qualifying IEEPA duties.
That means an importer needs to separate the IEEPA portion of an entry from Section 232,
Section 301, ordinary customs duties, and other charges.
For a stacked entry, that separation is essential.
Suppose an entry contains an ordinary duty, a Section 301 additional duty, and an IEEPA duty.
A qualifying IEEPA refund does not automatically create a refund for the Section 301 amount.
The same principle applies when Section 232 duties appear on the entry.
The authority must identify each duty and the classification under which it was assessed.
That gives the importer a clearer picture of what belongs in the IEEPA recovery calculation
and what needs a separate customs analysis.
Why Section 232 and Section 301 Duties Need Separate Treatment
The IEEPA ruling addressed duties imposed under IEEPA.
Section 232 and Section 301 operate under separate statutory authorities.
For importers, that means the IEEPA refund process should not be treated as a general credit against every tariff paid during the same period.
This distinction matters most when finance teams reconcile a refund against historical landed costs.
If an importer paid both Section 301 and IEEPA duties on an entry, the accounting records should continue to distinguish those amounts.
Recovering the qualifying IEEPA portion does not automatically erase the Section 301 amount from the historical cost of that shipment.
The same applies to Section 232.
Any separate recovery, exclusion, correction, protest, drawback, or other customs treatment involving Section 232 or Section 301 needs to be evaluated under the rules applicable to that program.
Compliance Risk: Assuming Your IEEPA Refund Makes You Whole
Receiving an IEEPA refund does not necessarily mean the importer has recovered every additional duty paid on the affected merchandise.
That assumption can create problems in landed cost calculations.
Consider an importer whose entries contain several duty layers.
If the finance team removes the entire historical tariff expense after receiving an IEEPA refund, the company’s records can understate the Section 232, Section 301, or other duty costs that remained associated with those entries.
That can affect margin analysis, inventory costing, pricing, purchasing decisions, and future forecasts.
A better approach is to reconcile the refund at the entry level.
Identify the original duty stack.
Identify the IEEPA amount.
Identify the amount actually recovered.
Then leave the remaining duty components in the landed cost calculation unless there is a separate basis for changing their treatment.
For importers with significant exposure to Chinese-origin goods or products covered by
Section 232 measures, that separation can meaningfully affect the numbers used to run the business.
Three Assumptions That Can Create Problems
1. Assuming the IEEPA Refund Makes You Whole on All Duties Paid
The IEEPA refund applies to the qualifying IEEPA layer.
Do not treat it as a refund of every duty charged on the same entry.
If Section 232 or Section 301 duties were also assessed, those amounts need to remain separate from the IEEPA recovery calculation.
The simplest way to avoid confusion is to reconcile the entry line by line.
Identify each duty type.
Identify the amount paid under each program.
Then match the refund to the specific IEEPA duties being recovered.
That gives the accounting team a more accurate picture of what came back and what remained part of the import cost.
2. Assuming Free Trade Agreement Status Automatically Eliminates Section 232 Exposure
Preferential tariff treatment under a Free Trade Agreement should not be treated as an automatic answer to a separate Section 232 question.
The importer still needs to determine whether an applicable Section 232 measure covers the merchandise and whether an exclusion or other specific treatment applies.
Base that analysis on the actual product, classification, country of origin, entry date, and applicable customs requirements.
For businesses importing from Free Trade Agreement partners, the important point is to keep the analyses separate.
First, determine the ordinary tariff treatment.
Then determine whether an additional Section 232 obligation applies.
Do not assume that receiving preferential treatment under one part of the tariff schedule automatically resolves the other.
3. Assuming Low-Value Shipments Do Not Need a Tariff Review
Do not use low shipment value as a shortcut for deciding whether Section 232, Section 301,
or another duty applies.
A shipment's treatment depends on the customs rules in effect at the time of entry and the specific merchandise involved.
For e-commerce businesses and direct-to-consumer importers, this matters because a
model built around low-value shipments can involve many entries.
A small mistake repeated across thousands of shipments can become a much larger customs and landed cost issue.
Importers should therefore review current entry treatment rather than assume a historical low-value shipment strategy will continue to produce the same duty result.
Across all three assumptions, the underlying lesson is the same:
Do not treat the tariff stack as one number.
Section 232, Section 301, IEEPA, ordinary duties, and other charges can appear together on the same entry, but they do not automatically receive the same legal or refund treatment.
Separate the duty layers first.
Then determine what each one means for recovery, compliance, and landed cost.
Special Rules That Do NOT Automatically Eliminate Section 232 or Section 301 Liability
Free Trade Agreement treatment, Foreign Trade Zone admission, low-value shipment rules, and other preferential customs programs should not be treated as automatic exemptions from Section 232 or Section 301 duties.
These programs operate under their own rules.
For an importer, the question is not simply whether the merchandise qualifies for preferential treatment somewhere else in the customs process.
The business still needs to determine whether an applicable Section 232 or Section 301 measure covers the merchandise and whether an exclusion, exemption, or other specific
treatment applies to that entry.
That analysis should be based on the actual product, country of origin, HTSUS classification, Chapter 99 classification, entry date, and customs treatment.
Free Trade Agreements Cannot Automatically Waive Section 232 Duties.
A Free Trade Agreement can affect the ordinary tariff treatment of qualifying merchandise.
It should not be treated as automatically eliminating a separate Section 232 additional duty.
For importers, those are two different parts of the entry analysis.
A product can qualify for preferential treatment under an applicable trade agreement and still require a separate Section 232 review.
That is particularly important for businesses importing steel, aluminum, copper, or products potentially covered by Section 232 measures.
Do not stop the analysis after confirming preferential tariff treatment.
Look at the product classification.
Review the applicable Chapter 99 provisions.
Determine whether Section 232 applies.
Then determine whether a product-specific exclusion, exemption, or other applicable treatment changes the result.
For importers working with goods from Canada, Mexico, or another Free Trade Agreement partner, keeping those analyses separate can prevent a landed cost model from overlooking
an additional duty.
The fact that the ordinary duty rate is reduced or eliminated under a trade agreement does not, by itself, answer the Section 232 question.
Foreign Trade Zone Admission Does Not Automatically Eliminate Section 232 Duties
Foreign Trade Zones can affect when and how customs duties are handled, but admission into an FTZ should not be treated as automatically eliminating Section 232 exposure.
The status under which merchandise enters the zone matters.
So does the classification and treatment of the merchandise when it ultimately enters U.S. commerce.
For steel, aluminum, and other products potentially covered by Section 232 measures, an importer using an FTZ should identify the status assigned to the merchandise at admission and understand how that status affects the later consumption entry.
This is especially important when merchandise is admitted under privileged foreign status.
The duty treatment can depend on the classification and tariff measures applicable under the rules governing that status.
That means the FTZ should not be viewed simply as a way to eliminate an additional tariff.
It is part of the customs structure and must be accounted for correctly.
An importer should be able to answer several basic questions from its records.
What merchandise entered the zone?
What HTSUS classification applied?
What status was assigned at admission?
Were Section 232 provisions associated with the merchandise?
What happened to the goods inside the zone?
How were they ultimately entered into U.S. commerce?
Those details determine the customs treatment far more reliably than the assumption that
FTZ admission alone eliminates the duty.
Section 321 De Minimis: Do Not Rely on an Old Low-Value Shipment Model
Importers should also be careful not to rely on historical assumptions about Section 321 de minimis treatment.
Low-value shipment rules have changed, and an import model that worked under an earlier framework should not automatically carry over into current landed cost calculations.
This is especially important for e-commerce companies, direct-to-consumer sellers, and businesses that built fulfillment models around high volumes of low-value shipments.
You must evaluate the customs treatment of those shipments under the rules in effect when the merchandise enters the United States.
That includes determining whether ordinary duties or additional tariff programs apply.
A low declared value does not eliminate the need to classify the merchandise correctly, determine country of origin, identify applicable tariff provisions, and calculate the duties
required under the current framework.
For companies importing thousands of smaller shipments, the financial impact can add up quickly.
A small duty error on one shipment can become a much larger problem when the same assumption repeats across an entire fulfillment operation.
Treat Each Customs Program Separately
The same issue applies throughout the tariff stack.
Different customs programs do different things.
A Free Trade Agreement can affect one part of the duty calculation.
An FTZ can affect how merchandise is treated and timed through the customs process.
Low-value shipment rules can affect how certain entries are handled.
Section 232 and Section 301 impose their own additional duty requirements when applicable.
Do not combine these programs into a single assumption about whether duties are owed.
For importers, the safer approach is to work through the entry in order.
Confirm the merchandise.
Confirm the country of origin.
Confirm the HTSUS classification.
Identify the Chapter 99 provisions.
Determine whether preferential treatment applies.
Determine whether Section 232 or Section 301 applies.
Then identify any exclusion, exemption, or other treatment that changes the result.
The same discipline matters when the company reviews historical entries for an IEEPA
refund.
The goal is not to remove every tariff from the entry.
The goal is to identify each duty correctly, determine how that duty should be treated, and ensure the company’s customs records and landed cost calculations reflect what actually happened.
What U.S. Importers Must Do Now to Manage Ongoing Duty Obligations
For U.S. importers, the first step is getting a clear picture of what is actually showing up on the customs entries.
That means separating Section 232, Section 301, IEEPA, and other duty amounts instead of treating total tariff expense as one number.
It also means checking entry status and applicable deadlines before assuming there is still time to pursue a potential IEEPA recovery.
The goal is to know what the company paid, why it paid it, what still affects landed costs, and what portion of the historical duty stack could still require separate recovery analysis.
Auditing Your Entries for Section 232 and Section 301 Exposure
Start with the ACE entry data.
Pull the relevant entry summaries and identify the Chapter 99 classifications attached to each entry.
For each entry, note:
Which Chapter 99 heading applies, including Section 232, Section 301, or IEEPA
Whether multiple Chapter 99 headings appear on the same entry
The duty amount paid under each heading separately.
This ACE data and customs entry review process gives the importer a clearer picture of what was actually entered and paid.
That matters because broker summaries, invoices, and accounting totals do not always provide the detail needed to separate each tariff layer.
The underlying entry records do.
For example, a finance report could show $300,000 in total tariff expense without clearly separating how much came from Section 301, Section 232, IEEPA, or another duty.
That total is not enough for a refund analysis.
The importer needs to know which entries generated the charges and which tariff authority produced each amount.
Once those amounts are separated, the business can begin reconciling its customs records with its accounting records and landed cost calculations.
The same review can also identify entries where more than one tariff program was applied.
Those stacked entries deserve attention because recovering one duty component does not automatically change how the others are treated.
Do Not Lose Track of the Protest Deadline
Entry status matters just as much as duty type.
For entries where a customs protest is the appropriate recovery path, the applicable customs protest 180-day deadline can be critical.
That deadline is tied to the customs action and entry involved, which means an importer with hundreds or thousands of entries can be dealing with different dates across the same portfolio.
Do not assume that all entries share one refund deadline.
Do not assume that work being done on a CAPE filing automatically preserves a separate protest right.
And do not wait until the end of a portfolio review to identify liquidation dates.
Include liquidation status in the entry audit from the beginning.
For each potentially recoverable entry, identify the relevant dates and determine whether a protest or another customs procedure applies.
That gives the importer a much better chance of addressing time-sensitive entries before an available filing window closes.
Recalculating Landed Costs as Tariff Rules Change
Importers should also update landed cost models when tariff rules affecting their products or
sourcing countries change.
A landed cost model is only useful if it reflects the tariff treatment that actually applies to current entries.
Do not assume that the duty structure from an earlier shipment still applies.
Product classification can matter.
Country of origin can matter.
Entry date can matter.
Chapter 99 classifications can matter.
New tariff measures, exclusions, changes in existing measures, or other customs
developments can change the calculation.
For importers sourcing across multiple countries, this review should be detailed enough to show which tariff programs affect each product-origin combination.
The company can then use those numbers when making pricing, margin, sourcing, purchasing, and inventory decisions.
This becomes especially important when a business receives an IEEPA refund.
Reconcile the refund against the IEEPA portion of the historical entries.
It should not automatically be used to reduce Section 232, Section 301, or other duty costs
that remain separate from that recovery.
For companies navigating changing Section 301 measures, evaluate the Section 301 tariff landscape affecting multiple trading partners against the company’s actual sourcing countries, products, classifications, and entry dates.
The important question is not whether tariffs generally went up or down.
It is what the company must pay on the merchandise it is importing now.
When to Consult a Tariff Recovery Specialist
A tariff recovery review becomes especially important when an importer has a large volume of historical entries, several Importer of Record entities, multiple customs brokers, stacked tariff programs, or entries approaching important customs deadlines.
The first job is separating the recoverable analysis from the ongoing compliance analysis.
For potential IEEPA recovery, identify the entries containing qualifying IEEPA duties and
determine their status.
For Section 232 and Section 301, identify the amounts separately and determine how those duties affect the company’s current and historical landed costs.
Those are related questions, but they are not the same question.
Singer Tariff Recovery works with importers from the customs records forward.
That starts with ACE data, entry summaries, Importer of Record information, Chapter 99 classifications, duty amounts, liquidation status, and applicable deadlines.
From there, the importer can see which duty layers connect to a potential IEEPA recovery and which should remain part of a separate Section 232, Section 301, or broader customs analysis.
That records-first approach is especially useful when the company’s accounting system shows a large tariff expense but does not clearly explain where each dollar came from.
Instead of working backward from a total number, start with the entries.
Identify what was paid
Identify why it was paid.
Separate the tariff programs.
Check the status of the entries.
Then determine what happens next.
For an importer managing both historical refund opportunities and ongoing tariff costs, that separation creates a much clearer picture of what could potentially come back to the business and what still needs to be built into its import costs.
Common Mistakes to Avoid
Even when an importer understands that IEEPA, Section 232, and Section 301 are separate tariff programs, mistakes can happen when those duties are reconciled across customs
records, accounting systems, and landed cost models.
The most common problems come from treating different tariff programs as if they all receive the same treatment.
They do not.
Identify each duty separately and evaluate it under the rules that apply to that specific program.
Treating the IEEPA Refund as a General Tariff Credit
An IEEPA refund should not be treated as a general credit against every tariff or duty paid on the same entry.
The recovery applies to the qualifying IEEPA portion.
If the entry also includes Section 232, Section 301, ordinary customs duties, or other charges, those amounts must remain separate unless another basis changes their treatment.
This matters when the refund reaches the company’s accounting system.
A finance team that applies the refund against the total historical tariff expense can create an inaccurate picture of what the business actually paid under each tariff program.
Instead, match the recovery back to the entries and the IEEPA duties connected to those entries.
Then reconcile the remaining duty layers separately.
That gives the business a clearer historical record and a more accurate basis for future landed cost calculations.
Applying FTA Preferential Rates as a Substitute for Section 232 Analysis
Analyze Free Trade Agreement treatment and Section 232 treatment separately.
An importer can qualify for preferential treatment under an applicable trade agreement and still need to determine whether a separate Section 232 measure applies to the merchandise.
Do not use the preferential ordinary duty rate as the end of the analysis.
Look at the merchandise.
Confirm the HTSUS classification.
Review the applicable Chapter 99 provisions.
Determine whether a Section 232 measure applies.
Then identify whether an exclusion, exemption, or other specific treatment changes the result.
For importers sourcing from Canada, Mexico, or other Free Trade Agreement partners, this distinction matters most when the merchandise includes products potentially covered by
Section 232 measures.
Preferential treatment under one customs program should not be assumed to eliminate
obligations arising under another.
Failing to Update Landed Cost Models When Tariff Rules Change
A landed cost model built around an earlier tariff structure can become inaccurate when the rules affecting the company’s imports change.
That can happen when a tariff program begins or ends, rates change, product coverage changes, an exclusion becomes available or expires, or another customs rule affects how
the merchandise is entered.
For a company importing from several countries, one general tariff percentage is rarely enough.
The model should account for the product, country of origin, HTSUS classification, Chapter 99 classifications, entry date, and additional duties that apply to the merchandise.
This is also why you should incorporate an IEEPA refund carefully.
Recovering a qualifying IEEPA duty changes that specific historical cost.
It does not automatically change the Section 232 or Section 301 treatment of the same merchandise.
Finance and customs should use the same entry-level information when those numbers are updated.
Assuming Foreign Trade Zone Admission Defers Section 232 Indefinitely
Foreign Trade Zone admission does not mean an importer can stop tracking Section 232 treatment.
The status assigned to the merchandise when it enters the zone can affect how the goods are treated when they later enter U.S. commerce.
For merchandise potentially subject to Section 232, importers should know how the goods were admitted, what classification applied, and how the later consumption entry was handled.
That is especially important when merchandise enters an FTZ under privileged foreign status.
The records should show the relevant admission information and provide enough detail to determine the tariff treatment when the goods leave the zone for U.S. consumption.
Do not assume that moving merchandise through an FTZ permanently removes an additional duty.
The FTZ structure needs to be analyzed as part of the overall customs treatment of the goods.
Missing the Protest Deadline on IEEPA-Eligible Entries
The duty layer that could qualify for IEEPA recovery still needs to be handled within the
applicable customs process.
That makes entry status and timing important.
An importer can correctly identify an IEEPA duty and still create a problem by waiting too long to determine whether a protest is required for a particular entry.
This becomes harder when the company has a large portfolio.
Different entries can liquidate at different times.
That means the business should not treat its entire IEEPA recovery as having one universal deadline.
Track liquidation dates and applicable filing periods at the entry level.
The same applies when a company is working on CAPE activity.
Do not assume that one part of the recovery process automatically preserves every other customs remedy or deadline.
Identify which process applies to the entry and track the corresponding dates.
Keep the Duty Layers Separate
All five mistakes come back to the same issue.
An importer’s tariff expense is not necessarily one legal obligation.
A single entry can contain several duty components, each with its own authority, classification, treatment, and potential recovery path.
That means the business should be able to look at an entry and identify what each amount represents.
What was ordinary customs duty?
What was Section 232?
What was Section 301?
What was IEEPA?
Were other additional duties assessed?
Which amounts remain part of the landed cost?
Which amounts require separate customs analysis?
Which entries have deadlines that need immediate attention?
Answering those questions using the underlying customs records gives the importer a more reliable picture than relying on a single tariff total.
It also helps prevent an IEEPA refund from being misunderstood as something broader than
it is.
The goal is not simply to recover money.
It is to know exactly what the company paid, what it recovered, what obligations remain, and what those numbers mean for the business going forward.
Frequently Asked Questions
Are Section 232 and Section 301 duties still owed after the Supreme Court ended IEEPA tariffs?
Yes, when the merchandise is subject to an applicable Section 232 or Section 301 measure.
The Supreme Court’s February 20, 2026 IEEPA ruling addressed tariffs imposed under IEEPA. It did not automatically eliminate duties imposed under Section 232 of the Trade
Expansion Act of 1962 or Section 301 of the Trade Act of 1974.
For importers, that means the duty programs need to remain separate.
If an entry contains a qualifying IEEPA duty along with Section 232 or Section 301 duties, the potential recovery of the IEEPA portion does not automatically eliminate the other duty amounts.
The importer still needs to determine which tariff programs apply to the merchandise based on the product, country of origin, classification, entry date, Chapter 99 provisions, and any applicable exclusions or other treatment.
Can I get a refund on Section 232 or Section 301 duties I have already paid?
No, not through the IEEPA refund process, simply because those duties appeared on the same entry.
The IEEPA recovery process applies to qualifying IEEPA duties.
Section 232 and Section 301 duties need to be evaluated separately under the customs rules and procedures applicable to those programs.
That distinction matters when an entry includes several duty layers.
An importer should not take the total amount paid to CBP and assume the entire figure belongs in an IEEPA refund calculation.
Instead, identify each duty separately.
If there is another basis for seeking a correction, exclusion-related treatment, drawback, protest, or other customs remedy involving Section 232 or Section 301, that needs its own analysis.
Does my Free Trade Agreement with the United States exempt my goods from Section 232 duties?
A Free Trade Agreement should not be treated as an automatic exemption from a separate Section 232 measure.
Preferential tariff treatment and Section 232 treatment are different parts of the customs analysis.
An importer should first determine the ordinary tariff treatment of the merchandise and then separately determine whether Section 232 applies.
That review should consider the product, HTSUS classification, Chapter 99 provisions, country of origin, entry date, and any applicable exclusion, exemption, or other specific treatment.
For businesses importing from Canada, Mexico, or another Free Trade Agreement partner, qualifying for preferential treatment under the agreement does not by itself answer the
Section 232 question.
Can a single shipment be subject to both Section 232 and Section 301 duties at the same time?
Yes, depending on the merchandise, country of origin, classification, and tariff provisions that apply to the entry.
This is tariff stacking.
A product can fall within an applicable Section 232 measure while also being subject to an applicable Section 301 duty.
When that happens, the importer needs to identify and calculate each applicable duty component separately.
That is why Chapter 99 classifications matter when reviewing an entry.
They show which additional duty programs were applied and help the importer better separate Section 232, Section 301, IEEPA, and other charges.
For refund purposes, that separation matters.
A qualifying IEEPA recovery applies to the IEEPA component. It should not automatically apply to every other tariff on the entry.
What replaced IEEPA tariffs after the Supreme Court ruling?
The tariff environment continued to change after the IEEPA ruling, with other tariff authorities and measures affecting imports during the period that followed.
For an importer, the key point is that those measures must be analyzed separately from the IEEPA duties being considered for recovery.
A change to one tariff program does not automatically remove Section 232, Section 301, or another additional duty from an entry.
The applicable treatment depends on the legal authority, effective dates, product coverage, country of origin, classification, and other requirements tied to the specific tariff measure.
That is why businesses should avoid using a single historical tariff rate when calculating current landed costs.
The tariff structure attached to a product can change over time.
Evaluate current entries under the requirements in effect when the merchandise is entered.
What should importers know about newer Section 301 measures?
Importers should evaluate Section 301 measures based on the products, countries, classifications, effective dates, and requirements applicable to the specific measure.
For an importer, the existence of a new or changed Section 301 measure does not eliminate the need to account for other duties that can apply to the same merchandise.
The company should determine whether its sourcing countries and products fall within the applicable Section 301 coverage and then identify any other tariff programs attached to those entries.
That review should be reflected in the landed cost model.
Do not assume that the expiration or removal of one tariff means the company’s overall duty burden decreased by the same amount.
The business needs to calculate what actually applies to the merchandise being imported.
The IEEPA Refund Is One Part of the Duty Picture
For U.S. importers, the end of IEEPA tariffs did not turn every tariff paid during the same period into a refund.
Section 232, Section 301, IEEPA, ordinary customs duties, and other charges need to be separated.
That separation matters for refund recovery.
It matters for customs compliance.
And it matters for the financial decisions the business makes using landed cost data.
An importer that receives an IEEPA refund should be able to identify exactly which entries produced that recovery and which duty amounts were returned.
The company should also know which Section 232, Section 301, and other duty amounts remain associated with those entries unless a separate customs basis changes their
treatment.
Apply the same discipline to current imports.
Start with the product.
Confirm the country of origin.
Check the HTSUS classification.
Identify the Chapter 99 provisions.
Separate the duty layers.
Then calculate the actual landed cost.
Do not build pricing, margins, sourcing decisions, or forecasts around the assumption that one tariff ruling changed every duty attached to the merchandise.
Know What You Paid Before You Calculate What You Can
Recover
A tariff refund analysis should begin with the customs entries, not the total tariff expense shown on a financial statement.
Singer Tariff Recovery works with U.S. importers to identify the duties appearing on their entries, separate qualifying IEEPA amounts from other tariff programs, review liquidation status, and identify deadlines that could affect the recovery process.
That records-first approach gives the business a clearer picture of two different numbers:
What could potentially be recovered from qualifying IEEPA duties?
What duties still need to be accounted for separately?
Both numbers matter.
If your company paid IEEPA duties while also carrying Section 232, Section 301, or other additional duties, book a call with Singer Tariff Recovery or call (917) 905-8280.
We can start with the underlying customs records and help identify what was paid, which duty programs were involved, and which entries need attention.
About the Author
Jeb Singer is the Managing Partner of J. Singer Law Group, PLLC, and a co-founder of Singer Tariff Recovery. He was admitted to practice in New York in 2009 and founded J. Singer Law Group in November 2014.
Earlier in his career, Jeb served as a law clerk to the Honorable Stuart M. Bernstein of the U.S. Bankruptcy Court for the Southern District of New York. His practice includes commercial litigation, bankruptcy, restructuring, and business matters involving complex financial and contractual issues.
Through Singer Tariff Recovery, Jeb works with U.S. importers evaluating potential IEEPA tariff recovery opportunities. That work begins with the underlying customs records, including ACE data, Importer of Record information, duty amounts, liquidation status, filing requirements, and applicable deadlines.
For businesses dealing with multiple tariff programs on the same entries, that records-first approach helps separate the potential IEEPA recovery from Section 232, Section 301, and other duty obligations that require their own analysis.
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