Did You Overpay Section 232 Duty on Taiwan Auto Parts? How to Claim It Back

The cap comes from a January 2026 memorandum of understanding between the American Institute in Taiwan and the Taipei Economic and Cultural Representative Office, implemented at 91 FR 31818 and published May 28, 2026 — not, as much commentary has it, from the February 2026 Agreement on Reciprocal Trade, which was signed on February 12, 2026 but had not entered into force.

The mechanism caps a total rather than adding a layer. Where a covered part's Column 1 General rate is already 15% or higher, no Section 232 duty applies; where Column 1 is below 15%, Section 232 duty is limited so the two together reach 15%. Those outcomes sit in HTSUS headings 9903.94.66 through 9903.94.69. The un-capped auto-parts baseline, heading 9903.94.05, is the applicable subheading rate plus 25%. The gap between the two is the money at stake. Covered parts are also exempt from the derivative steel, aluminium and copper Section 232 duties in headings 9903.82.02 and 9903.82.04 through 9903.82.19 — a second, separate overpayment vector.

The party who can file is the importer of record — not the supplier, not the forwarder. Three fact patterns are worth checking against your entry summaries.

This is the part that catches small importers. CBP's post summary correction guidance gives filers 300 days from the date of entry, and up to 15 days before the scheduled liquidation date, "whichever date is earlier." Outside that window ACE rejects the filing automatically. Most people read the headline and hear 300 days — but CBP describes its normal liquidation cycle as 314 days from entry, and fifteen days before day 314 is day 299. On an ordinary entry the second limb binds first, so the real window is a hair under 300 days rather than a comfortable 300. On a May 1, 2026 entry it closes around late February 2027, earlier if liquidation was scheduled ahead of the usual cycle.

A correction is only available while the entry summary has been accepted, paid, is in CBP control, is not under CBP review, and has not liquidated. One caveat: it runs as an ACE test programme under 19 CFR 101.9(b), so it is CBP guidance rather than a codified deadline. Once an entry liquidates that route closes, and CBP points filers at a prior disclosure or a protest instead. The protest deadline is a regulation rather than guidance: 180 days from the date of notice of liquidation, under 19 CFR 174.12(e), implementing 19 U.S.C. 1514.

Send this as a list, not as a general question about tariffs. Every item is something only they can see.

Part of the documentation sits with your manufacturer. Ask your broker which of these they need — that list is theirs to set.

Sometimes not. The gap between an un-capped auto-parts line and a 15% total is real money on a container of body panels and close to nothing on a pallet of low-value hardware, so run the arithmetic per entry with your broker's fee in front of you. Look at the marginal entries anyway: the same classification question is probably repeating on your live ones.

All of this turns on whether your classification is on the Section 232 list, and no article can see your classification. If anyone tells you confidently what your duty rate is without having looked at your entry summaries, treat that as marketing. Stated as of August 1, 2026 — verify the current position with your customs broker before relying on any of it, and re-check by September 1, 2026, or immediately if the Agreement on Reciprocal Trade enters into force or the Annex to 91 FR 31818 is amended.

Separately from any refund: if the exercise turns up parts where your current supply is why the classification is awkward, that is a sourcing question. Describe the part in plain English on our request page — vehicle, years, position, volumes — and we come back with verified Taiwan manufacturers that have confirmed they want the project.