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Chapter 99 Tariff Stack Guide for Section 301, 122, and 232

Chapter 99 tariff recovery depends on sequencing. For entries with multiple special tariff programs, CBP guidance instructs filers to report Chapter 98 first if applicable, then Chapter 99 trade remedies in a specific order, then the Chapter 1-97 commodity tariff. That sequence matters for landed-cost analytics, drawback, PSCs, protests, and audit trails.

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Why Chapter 99 stacks are difficult

Enterprise importers may have Section 301, Section 122, Section 232, Section 201, exclusions, quotas, Chapter 98 treatment, FTZ treatment, and ordinary duties on the same shipment. The result is not just a higher duty bill. It is a line-level evidence problem.

If the Chapter 99 stack is wrong, later recovery work becomes slower and less reliable.

Sequence to preserve

CBP Section 122 guidance gives a trade remedy sequence for applicable Chapter 99 reporting:

SequenceReporting layer
1Chapter 98, if applicable
2Chapter 99 additional duties
3Section 301 Chapter 99
4Section 122 Chapter 99
5Section 232 Chapter 99
6Section 201 duties, if applicable
7Section 201 quota, if applicable
8Chapter 99 replacement duty or other use provisions
9Other Chapter 99 quota provisions not covered above
10Chapter 1-97 commodity tariff

What this means for refund work

Drawback, PSCs, protests, exclusions, CAPE-style workflows, and litigation-driven refunds all need the entry line to tell the same story. A strong recovery program preserves:

  • Every Chapter 99 heading on the entry line
  • The underlying Chapter 1-97 HTS
  • Quantity and value in ACE order
  • Country of origin and special program claims
  • Duties, taxes, fees, and trade remedy amounts paid
  • Liquidation and protest status
  • Export, destruction, or manufacturing evidence

Ready to find out what you've been missing? Book a call with the Pax team.

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Ready to find out what you've been missing? Book a call with the Pax team.

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