Auto Parts Importers: A Complex IEEPA Landscape
The auto parts industry has one of the most complex IEEPA eligibility situations of any sector, because its major supply countries — Canada, Mexico, and South Korea — all have FTA agreements with the United States that can exempt qualifying goods from IEEPA duties.
Understanding exactly which of your entries paid IEEPA duties (and are refundable) requires careful entry-by-entry review. The potential refunds are significant for entries that did pay IEEPA duties, but many entries may not qualify due to FTA treatment.
Key Product Categories
Chapter 87 — Vehicles and Parts
- 8708.29: Parts and accessories of bodies (panels, bumpers, doors)
- 8708.40: Gearboxes and parts
- 8708.50: Drive-axles and non-drive axles
- 8708.70: Road wheels and parts and accessories
- 8708.91: Radiators and parts
- 8708.99: Other parts and accessories for motor vehicles
- 8512.20: Electrical lighting equipment for vehicles
Other Relevant Chapters
- 4011.10: New pneumatic tires for passenger cars
- 8483.10: Crankshafts and camshafts
- 7320.20: Helical springs (suspension components)
Canada and Mexico: The USMCA Factor
Canada and Mexico are two of the largest sources of auto parts for U.S. assemblers and the aftermarket. The USMCA significantly affects eligibility:
USMCA-qualifying goods: Parts that met USMCA rules of origin and entered duty-free because of USMCA treatment paid $0 in IEEPA duties. There is no refund for these entries.
Non-USMCA-qualifying goods: Parts that did not meet USMCA rules of origin (due to insufficient regional content, third-country origin of components, or other reasons) and paid the 25% IEEPA rate are eligible for refund.
In practice, modern automotive supply chains are complex, and many parts have mixed origin situations. Review your entries on a line-by-line basis with your customs broker.
South Korea: KORUS FTA
South Korea received a 10% IEEPA rate. However, KORUS FTA-qualifying goods entered duty-free and paid no IEEPA duty. Korean auto parts that did not qualify under KORUS — typically those with insufficient Korean content — paid the 10% rate and are eligible for refund.
Japan: Simpler Situation
Japan does not have a current FTA with the United States, so Japanese auto parts received the full 10% IEEPA rate without FTA complications. This makes Japanese-origin entries more straightforward to evaluate for CAPE eligibility.
Section 232 Auto Tariffs
Separate from IEEPA, the administration imposed 25% Section 232 tariffs on imported automobiles and auto parts (with some exemptions). Section 232 tariffs are not refundable through CAPE. If your entries from Canada, Mexico, or other countries show Section 232 duties, those are separate from — and not part of — any IEEPA refund.
Filing Strategy
Given the complexity of FTA interactions in this sector, auto parts importers are strong candidates for working with a customs broker or recovery partner who can perform the line-by-line FTA qualification review before preparing the CAPE CSV. Claiming entries that were FTA-exempt is a common error for this industry and results in submission delays.