Ireland (EU) IEEPA Reciprocal Tariffs: Rates, Exemptions, Timeline, and Refund Notes

June 2026 policy watch

• USTR's forced-labor Section 301 proposed action includes the European Union listing relevant to this EU member state. The proposed rates are not current IEEPA or Section 122 duties; watch the June 22 appearance-request deadline, July 6 written-comment deadline, and July 7 hearing before changing entry models.
• Keep IEEPA refunds, Section 122 entries, Section 232 duties, and Section 301 proposed actions in separate workpapers. A country profile can overlap with several Chapter 99 programs, but CAPE remains an IEEPA refund workflow.

Informational only — not legal advice.

Default Rate Ladder (10-second answer)

EU “Top-Up to 15%” (Aug 7 onward): what it means in practice

CBP described the EU rule as:

• If your EU-origin good’s Column 1 duty rate is equal to or greater than 15%, the reciprocal additional duty is 0% (file 9903.02.19). (CBP CSMS #65829726)
• If the Column 1 duty rate is less than 15%, the sum of the Column 1 duty rate plus the reciprocal additional duty rate equals 15% (file 9903.02.20). (CBP CSMS #65829726)

Simple example (illustrative): if your base Column 1 duty rate is 2.5%, the reciprocal add-on would typically be 12.5% so the total becomes 15%.

Lookup Algorithm (how to get to the right Chapter 99 + rate)

1. Identify the entry date/time (ET) for the line.
2. Confirm the country of origin is Ireland (EU origin rules matter for the reciprocal program).
3. Check whether the entry qualifies for an in-transit exception.
   • Loaded before 2025-04-05 and entered before 2025-06-16 12:01 a.m. EDT (extended). (CBP CSMS #65201773)
   • Loaded before 2025-08-07 and entered before 2025-10-05 12:01 a.m. EDT (Aug 7 transition). (CBP CSMS #65829726)
4. Check whether the line qualifies for a reciprocal exception heading (Annex II, Section 232 goods, >=20% U.S. content rule). (CBP CSMS #64680374)
5. Apply the reciprocal rate heading for the relevant period:
   • Baseline/suspension: 9903.01.25 (+10%). (CBP CSMS #64680374)
   • One-day EU rate: 9903.01.50 (+20%) on 2025-04-09. (CBP CSMS #64680374)
   • EU Aug 7 top-up structure: 9903.02.19 (0%) or 9903.02.20 (top-up to 15%) depending on the Column 1 rate. (CBP CSMS #65829726)
6. For entries within the Section 122 window, evaluate Section 122 headings (9903.03.01–9903.03.11) and Annex II exclusions. (CBP CSMS #67844987)

Default Rule + Major Exceptions (fast lookup)

Timeline (what changed, when)

HTS / Chapter 99 Code Lookup (simplified)

Operational Notes (what matters for refunds)

1. CAPE Phase 1 is now the IEEPA refund workflow. CBP announced Phase 1 for eligible IEEPA refunds in ACE beginning April 20, 2026. Country-specific refund work still runs through entry records, importer-of-record status, liquidation timing, and duty-type separation. Section 122 (9903.03.*) is separate: the May 7 CIT ruling invalidated Proclamation No. 11012, the government appealed, the Federal Circuit entered an administrative stay on May 12, and the CIT denied the government's separate stay request on May 20. Unless the Federal Circuit modifies or lifts its administrative stay, the ruling does not make Section 122 lines eligible for IEEPA CAPE. (CBP CSMS #68315804, CIT Slip Op. 26-47, CIT Slip Op. 26-53)
2. EU is the “country” object for reciprocal administration. CBP’s April 9 rate table treats EU member states (including Ireland) as an “EU” bucket for reciprocal rate headings. (CBP CSMS #64680374)
3. Aug 7 EU logic depends on your base HTS duty rate. This can create line-by-line differences on the same entry if HTS duty rates differ. (CBP CSMS #65829726)
4. Replacement duty reporting can change how the 7501 looks. For the EU “top-up” path (9903.02.20), CBP described reporting the 15% duty on the Chapter 99 line and 0 duty (with line value) on the Chapter 1–97 line. (CBP CSMS #66319804)
5. Drawback is available for reciprocal tariffs. CBP stated drawback is available for reciprocal tariff duties (and for Section 122). (CBP CSMS #64680374, CBP CSMS #67844987)
6. IEEPA ended does not mean other duties ended. CBP noted the termination affected IEEPA duties only (Section 232/301 etc are separate). (CBP CSMS #67834313)