Machinery importers and IEEPA
Machinery imports often stack Section 232 (steel and aluminum content) with IEEPA. The Section 232 layer is material — 25% on steel-content lines, 10% on aluminum — and it stays with CBP. IEEPA on top was typically 7.5%–25%. Clean separation is essential; a spreadsheet that claims the full stacked amount will fail CBP's VAL-E validation.
Common HTS chapters in scope
- Chapter 84 — machinery and mechanical appliances
- Chapter 85 — electrical industrial equipment
- Chapter 87 — vehicles and trailers
- Chapter 90 — instruments and apparatus
- Section 232 steel-derivative HTS codes layered with IEEPA
Why the cliff matters for machinery
Capital-goods entries liquidate slowly — often near the full 314-day CBP review window. This is actually an advantage: many machinery entries from mid-2025 are still unliquidated in mid-2026, which means no cliff pressure yet. File the liquidated ones early, queue the unliquidated ones for batched submission.
Typical refund structure
Per-entry refunds for machinery run larger than apparel or consumer electronics because unit values are higher. A single $2M CNC machine entry with a 10% IEEPA layer is a $200K principal refund plus interest. Volume of entries is lower (tens to low hundreds per year), so the total refund book tends to be in the mid-six-figure to low-seven-figure range for mid-size industrial importers.
HTS chapters in scope
| HTS Chapter | Typical product | IEEPA scope | Typical duty rate (IEEPA-affected entries) |
|---|---|---|---|
| Chapter 84 | Nuclear reactors, boilers, CNC machines, pumps, compressors, mechanical appliances | Overlap with Section 232 | additional IEEPA rate |
| Chapter 85 | Electric motors, generators, transformers, industrial control panels | Fully covered | additional IEEPA rate |
| Chapter 73 | Iron and steel articles — industrial brackets, fittings, structural parts | Overlap with Section 232 | varies |
| Chapter 82 | Tools, implements, cutlery — industrial hand tools, cutting implements | Fully covered | additional IEEPA rate |
Typical refund bands for this sector
These bands reflect typical IEEPA exposure observed across public trade-data aggregates for the sector. Actual refund depends on your specific HTS mix, origin country, and exclusion profile — run the free calculator for your numbers.
| Typical dutiable value | Typical IEEPA exposure % | Typical refund band (low–high) |
|---|---|---|
| $500K | 8–15% | $40K–$75K |
| $2M | 8–15% | $160K–$300K |
| $10M | 8–15% | $800K–$1.5M |
Cost comparison for this industry
A $220K machinery refund at a 15% broker contingency costs $33,000 in fees. un-tariff's Standard tier ($799) handles the same filing for under 0.4% of the refund.
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 machinery volume. If the number warrants it, see pricing for the flat-fee filing tiers.
Common questions
Do Section 232 derivative rules stack with IEEPA?
Yes. Section 232 on steel and aluminum content — including the derivative-product extensions covering downstream machinery — was still in effect throughout the IEEPA window. Entries that paid both stack cleanly; only the IEEPA piece refunds.
What about entries where only part of the machine is derivative-scope?
CBP applies Section 232 at the HTS-line level, not the component level. If the HTS line is within the derivative list, the line pays Section 232 on the stated dutiable value. un-tariff treats the HTS line as atomic and separates IEEPA from Section 232 at that level.
Our equipment is capitalized — does that affect the refund?
No. The refund is paid to the importer of record in cash, regardless of accounting treatment. The tax handling of the refund (ordinary income vs reduction of capitalized basis) is a matter for your controller or tax advisor.
Can I claim on entries that are still unliquidated?
Yes. CAPE Phase 1 accepts unliquidated entries. The principal computation happens at liquidation time on CBP's side. File when ready — the 80-day clock does not start until liquidation.