Automotive parts importers and IEEPA
Auto parts sit at the intersection of three tariff regimes: Section 232 on steel and aluminum derivatives, Section 301 on China-origin components, and IEEPA on top of both depending on the executive order. USMCA-qualifying parts (majority of North American supply chains) were excluded from most IEEPA tranches — when IEEPA was charged anyway, it's usually a preferential-claim error, not a CAPE matter.
Common HTS chapters in scope
- Chapter 87 — vehicles other than railway or tramway rolling stock, and parts and accessories thereof
- Chapter 40 — rubber and articles thereof (tires, hoses, belts)
- Chapter 73 — articles of iron or steel (auto-grade steel components)
- Chapter 76 — aluminum and articles thereof (auto-grade aluminum components)
- Chapter 84 — machinery (engine subcomponents, drivetrain)
- Chapter 85 — electrical machinery (wiring harnesses, sensors, control modules)
Why the cliff matters for auto parts
Just-in-time supply chains mean high entry frequency — a Tier-1 supplier can easily file thousands of entries per year. Liquidation timelines are standard 6–9 months. The cliff arrives in staggered waves; un-tariff's classifier aggregates per-entry so you can file in per-supplier batches without losing track of timing.
Typical refund structure
Aggregate refunds for large Tier-1 suppliers run well into seven figures, driven by volume rather than per-entry amount. Per-entry IEEPA principal averages $100–$2,000 for a typical parts shipment. The interest layer compounds meaningfully when filings take six months from payment to 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 auto parts volume. If the number warrants it, see pricing for the flat-fee filing tiers.
Common questions
How does USMCA interact with IEEPA for auto parts?
USMCA-qualifying auto parts (North American regional value content) were excluded from many IEEPA tranches. Charged IEEPA on USMCA-qualifying entries is typically an error. un-tariff flags these for preferential-treatment correction rather than CAPE; consult counsel for the correction filing.
Section 232 on steel and aluminum still applies — right?
Yes. Section 232 was not affected by the SCOTUS ruling. Steel and aluminum derivative-rule auto parts still pay Section 232. Only the IEEPA layer refunds.
Can I file CAPE per supplier or does it have to be per IOR?
CAPE is filed per IOR (importer of record). If you have multiple IORs across subsidiaries, each files its own CAPE. un-tariff's paid tool handles multi-entity IOR structures — each IOR gets its own CSV, its own ACH payer ID, its own tracking.
What if I import through a customs broker who is the IOR?
Rare for auto supply chains but it happens. In that case, the broker is the refund recipient. Your contract with the broker should address pass-through of any refunds. un-tariff treats whoever is on the entry record as the IOR — we do not decide the downstream arrangement.