Electronics importers and IEEPA
China-origin consumer electronics typically paid Section 301 at 7.5%, 15%, or 25% plus IEEPA at 7.5%–25% on top. CAPE refunds only the IEEPA layer. un-tariff's stacking rule IEEPA-005 separates the two cleanly per line — Section 301 stays with CBP, IEEPA refunds back. Getting this wrong in a spreadsheet is the single most common source of filing rejections for this industry.
Common HTS chapters in scope
- Chapter 84 — machinery and mechanical appliances (including computers)
- Chapter 85 — electrical machinery and equipment (including semiconductors, phones, consumer electronics)
- Chapter 90 — optical, photographic, measuring instruments
- Chapter 91 — clocks and watches
- Chapter 99 IEEPA Chapter 99 subheadings stacked on Section 301 List 1–4 codes
Why the cliff matters for electronics
Consumer electronics move fast. Entries filed in Q3 2025 are liquidating through Q2 2026, which means the 80-day cliff hits mid-to-late 2026. Distributors and retailers should audit liquidation dates now — by July the earliest entries start hitting cliffs.
Typical refund structure
Electronics importers frequently recover seven figures because volumes are high and IEEPA tranches were large. A $20M China-origin consumer-electronics book with 10% IEEPA layered on Section 301 25% recovers $2M of IEEPA principal plus interest — over $2.1M once compounded. The Section 301 piece ($5M in this example) stays with CBP.
How un-tariff helps
- Runs your ACE Entry Summary against the versioned IEEPA HTS registry — no manual lookups.
- Separates stacked Section 232 / Section 301 duty from IEEPA principal automatically, so the refund number is defensible.
- Flags every entry within 14 days of the 80-day cliff so the time-sensitive ones ship first.
- Computes CBP quarterly interest with the correct daily compounding across rate boundaries.
- Validates the CAPE CSV against all CBP VAL-F/E/I rules before you download — no surprise rejections.
Next steps
Start with the free calculator to see the refund band for your electronics volume. If the number warrants it, see pricing for the flat-fee filing tiers.
Common questions
Does IEEPA refund touch my Section 301 duties?
No. The SCOTUS ruling invalidated IEEPA only. Section 301 was imposed under a different statute (Trade Act §301) with explicit tariff authority. Section 301 duties stay collected. un-tariff separates IEEPA from Section 301 per-line and only the IEEPA amount flows to the refund.
What if my imports are from a country not on the Section 301 list but still paid IEEPA?
Non-China-origin electronics were subject to IEEPA tranches in some executive orders (the global 'Reciprocal Tariffs' set) but not to Section 301. Those entries should have a cleaner-than-China refund — the full IEEPA amount, with no Section 301 layer to separate.
What about component versus finished-goods entries?
IEEPA classification is HTS-based, not component/finished-based. A finished laptop (HTS 8471.30) and its LCD panel (HTS 9013.80) have different HTS subheadings and potentially different IEEPA treatments. un-tariff handles the per-line classification.
Do consumer-electronics exclusions apply?
Several IEEPA executive orders carved out specific HTS subheadings — for instance, some semiconductor codes had narrower IEEPA scope. The HTS registry includes these carve-outs so the classifier drops excluded lines automatically. Verify against CBP's IEEPA FAQ for your specific HTS codes.