IEEPA Tariff FAQs

Tariffs issued under the International Emergency Economic Powers Act (IEEPA) have been a mainstay during the second Trump Administration. They cover everything from automotive parts to coffee imports and impact all the U.S.’s trading partners in some way. Due to their wide reach, they have raised plenty of additional questions from importers, customs brokers, and others across the industry.  

CBP has compiled a running list of FAQs on their website addressing the different types of IEEPA tariffs. The following are a few of the most relevant questions, but we highly recommend referring to CBP’s page for any situation-specific guidance. 

What are the current unstacking provisions? 

• Products subject to Autos/Auto Parts 232 are not subject to Copper/Aluminum/Steel 232, nor to Reciprocal, Brazil, Russian Oil, or Canada/Mexico IEEPA tariffs.  
• Content subject to Section 232 Aluminum or Steel is not subject to Reciprocal, Brazil, Russian Oil, or Canada/Mexico IEEPA tariffs. 
• Content subject to Section 232 Copper is not subject to Reciprocal, Brazil, or Russian Oil IEEPA tariffs. 
• Products with a mixture of copper, steel, and/or aluminum content continue to be subject to all applicable Section 232 duties for each material. 

I imported goods that are country of origin Canada or Mexico. Are they subject to IEEPA Reciprocal Tariffs? 

• Exception 9903.01.26 is applicable to goods of Canada and exception 9903.01.27 is applicable to goods of Mexico.   
• 9903.01.26 (Canada) Articles the product of Canada, including those entered free of duty as under the United States-Mexico-Canada Agreement, and any applicable treatment set forth in Subchapter XXIII of Chapter 98 and Subchapter XXII of Chapter 99 of the HTSUS.  Articles properly classified in 9903.01.10 through 9903.01.15 must declare a secondary classification under 9903.01.26 to be excepted from the reciprocal tariff. 
• 9903.01.27: (Mexico) Articles the product of Mexico, including those entered free of duty as under USMCA and any applicable treatment set forth in Subchapter XXIII of Chapter 98 and Subchapter XXII of Chapter 99 of the HTSUS.  Articles properly classified in 9903.01.01 through 9903.01.05 must declare a secondary classification under 9903.01.27 to be exceptedfrom the reciprocal tariff. 

My goods are subject to an exclusion from Section 301 duties. Will they be subject to the additional duty on products of China imposed pursuant to IEEPA? 

• Yes. The additional ad valorem duty provided for under HTSUS 9903.01.20 and 9903.01.24 applies in addition to all other applicable duties (including Section 301 duties), taxes, fees, exactions, and charges. Even if goods are subject to an exclusion from Section 301 duties, if they are classified in HTSUS heading 9903.01.20 or 9903.01.24, they are subject to the additional ad valorem duty provided for in HTSUS heading 9903.01.20 or 9903.01.24. 

If an imported auto or auto part is subject to Section 232 duties, could it also be subject to IEEPA duties? 

• Articles subject to Section 232 duties on autos and auto parts under Proclamation 10908 (March 26, 2025), as amended, are not subject to the IEEPA duties imposed on products of Canada (EO 14193, as amended) or Mexico (EO 14194, as amended) as detailed in CSMS # 65236574 -UPDATED GUIDANCE – Proclamation “Adjusting Imports of Aluminum and Steel in the United States,” Amending Executive Order 14289, “Addressing Certain Tariffs on Imported Articles”. Nor to IEEPA Reciprocal duties (EO 14257, as amended) under heading 9903.01.33, HTSUS.  
• However, such articles may be subject to the IEEPA duties if they are products of China or Hong Kong (EO 14195, as amended). 

These are just a few of the many FAQs CBP has published throughout the year, and the agency continues to update its guidance as new questions arise across the trade community. If you would like further clarification, we recommend reviewing the CBP’s FAQ page or contact Scarbrough for assistance.