Section 301 List 4A vs. List 4B: Understanding the Split and What It Means for Your Refund

When the Office of the United States Trade Representative imposed Section 301 tariffs on Chinese goods in 2019, it divided the fourth tranche into two separate sublists. List 4A took effect September 1, 2019, and List 4B was scheduled to follow on December 15, 2019. That timeline matters because List 4B was suspended before it ever went into force, while List 4A began collecting duties immediately. Many importers treated the two lists as a single policy event, but they are legally and operationally distinct, and that distinction shapes what you can recover today.

How the Section 301 Tariff Tranches Are Structured

Section 301 tariffs were rolled out in four numbered tranches, each tied to a separate USTR investigation finding. The first three tranches covered industrial inputs, intermediate goods, and capital equipment. The fourth tranche targeted consumer-facing products that the USTR had initially tried to avoid, including laptops, smartphones, clothing, and footwear.

To manage political sensitivity around consumer prices, the USTR split the fourth tranche. List 4A captured products where the administration was willing to absorb immediate tariff impact. List 4B was held back, covering goods that were considered too price-sensitive to hit heading into the holiday retail season.

List 4A: Active Since September 2019

List 4A imposed a 15 percent Section 301 tariff on a broad set of HTS classifications covering electronics accessories, apparel, footwear, travel goods, and many consumer products. That rate stacked on top of the existing Most Favored Nation duty rate, meaning importers were paying a blended effective rate that often exceeded 20 percent.

Importers who sourced from China under List 4A HTS codes paid these duties continuously from September 1, 2019, forward. The USTR did open a product exclusion process for List 4A, and some importers secured temporary relief. However, many of those exclusions expired, and the underlying 15 percent rate remained in place for most goods throughout the relevant period.

When IEEPA tariffs were later layered on top, importers in List 4A categories faced some of the highest combined effective duty rates of any importer group in the country. That accumulation of duties is exactly what makes List 4A importers significant candidates for tariff overpayment recovery.

List 4B: Suspended Before It Started

List 4B was a different story. After the USTR announced the December 15, 2019, effective date, the phase-one trade deal negotiations with China led to a suspension of List 4B before it ever went live. The tariff was never collected. That means importers who exclusively sourced goods covered by List 4B HTS codes did not pay Section 301 duties on that tranche.

This creates an important practical point. If your goods fell only under List 4B classifications, your Section 301 exposure from that specific tranche was zero. However, many HTS codes appeared on multiple lists, and importers often sourced across a range of product categories. A business buying electronics accessories and apparel from China could easily have had exposure on List 4A while avoiding List 4B entirely.

Sorting out which of your historical entries touched List 4A versus List 4B requires pulling your ACE entry summary data and cross-referencing the HTS codes against the USTR annexes. This is not a casual spreadsheet exercise, but it is a necessary one if you want an accurate picture of your recoverable duties.

Why the List 4A and 4B Distinction Matters for IEEPA Refund Claims

The February 2026 Supreme Court ruling that found IEEPA tariffs unconstitutional opened a refund window for duties paid under those executive orders. The IEEPA tariffs were separate from Section 301 tariffs, but they overlapped significantly in practice because both applied to Chinese-origin goods. Many importers were paying Section 301 duties on their goods and then also paying IEEPA tariffs on top of that.

The IEEPA tariff refund claims being filed through CBP's CAPE portal cover the IEEPA layer specifically. Section 301 tariffs are not being refunded through that same channel because the constitutional ruling addressed IEEPA, not Section 301. However, understanding your Section 301 history is critical for two reasons.

First, your List 4A duties represent a significant cost baseline that shows the full scope of what you were paying on China-origin goods. Second, if any Section 301 exclusions applied to your HTS codes during the period when you also paid IEEPA tariffs, the interaction between the two tariff layers affects how you calculate the refundable amount. Importers who received product exclusions that offset their Section 301 rate were still paying IEEPA tariffs, and those IEEPA duties remain refundable within the filing deadlines.

Filing Deadlines You Cannot Afford to Miss

The refund deadline for IEEPA tariffs on Chinese goods is February 4, 2027. That date is statutory and CBP has no discretion to extend it. Claims must be filed through the CAPE portal before that date, covering duties paid on entries where China-origin goods were subject to IEEPA tariff orders.

If you also imported from Mexico or Canada under the fentanyl-related IEEPA orders, that same February 4, 2027, deadline applies. For reciprocal tariffs imposed on other countries, the deadline is April 5, 2027. Waiting until late in 2026 to begin the process creates serious risk because assembling entry summary data, verifying importer of record status, and completing CAPE portal submissions all take time.

What Happens After a Successful Claim

CBP issues approved refunds via ACH direct deposit. The payment includes the principal duty amount recovered plus statutory interest, which accrues from the date the duty was originally paid. That interest component is meaningful for importers who paid large volumes of IEEPA tariffs during the peak enforcement period. The typical timeline from claim filing to payment is 60 to 90 days, though that can vary depending on claim volume at CBP.

As of mid-2025, CBP had processed approximately $121.75 billion in claims, but roughly 93.5 percent of eligible importers had not yet filed. That gap exists partly because many importers do not know they qualify, and partly because the filing process requires specific technical knowledge of CBP systems and tariff regulations.

Practical Steps for China Importers With List 4A Exposure

• Pull your ACE entry summaries for the period from September 1, 2019, through the most recent IEEPA tariff period and identify every entry where China-origin goods were classified under List 4A HTS codes.
• Check whether any product exclusions were granted for those HTS codes during the relevant periods and confirm whether those exclusions were active at the time of each entry.
• Separate the Section 301 duty amounts from the IEEPA duty amounts on each entry, since only the IEEPA layer is currently refundable through the CAPE portal.
• Confirm that your business was the importer of record on the entries you are claiming, since refund rights belong to the importer of record, not the buyer or consignee.
• Verify that your ACH enrollment with CBP is active so that any approved refund can be deposited without delay.

Check Your Eligibility With Tarisol

Tarisol connects U.S. importers with the Tariff Refund Agency, a licensed specialist that files IEEPA tariff refund claims through CBP's CAPE portal on a success-based fee structure with no upfront cost. If you sourced goods from China and paid duties under IEEPA tariff orders, you may have a recoverable claim regardless of whether your products also carried Section 301 tariffs.

The February 4, 2027, deadline for China-origin IEEPA refunds is firm. Contact Tarisol today to check your eligibility, get a preliminary estimate of your recoverable duties, and start the process before the window closes.