I was answering technically/generically about whether an mp3 can clip if the source audio isn't clipping. But yeah, in this specific case, from the description the mp3 is not actually clipping. The RMS offset is +14dB by default, so it can read over zero even if there are no actual overs in the audio.
If it sounds like it's clipping but the meter's not showing red, it's probably just loss of dynamic range from the mp3 compression.
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