How to file a duty drawback claim

A US duty drawback claim is filed electronically in ACE on CBP Form 7551, the drawback entry, and refunds 99% of the eligible duties, taxes and fees paid on imported goods that were later exported, destroyed under customs supervision, or manufactured into exported articles. The legal basis is 19 U.S.C. §1313, implemented at 19 CFR Part 190.

The steps below are the sequence a claim actually moves through. They are educational: filing is done either through a drawback filer account with ABI access or through a licensed customs broker or drawback specialist, and most first-time claimants use the latter because the entry linkage and recordkeeping are where claims fail.

Step 1: confirm you have an eligible claim

Three questions, in order.

Was duty actually paid on an import? Drawback refunds duty paid. Goods that entered duty-free, or that came in under a duty-deferral programme where no duty was paid, have nothing to refund.

Did those goods, or validly substituted goods, leave US commerce in a recognised way? Export is the common trigger. Destruction under customs supervision qualifies on the same footing. Rejected merchandise returned to the supplier can qualify under §1313(d).

Are you inside five years? The export or destruction must fall within five years of the import date, and the claim must be filed within that same window.

Then identify which type you are claiming under — unused merchandise (§1313(j)), manufacturing (§1313(a) or (b)), or rejected merchandise (§1313(d)) — because it determines what evidence you need and whether a ruling is required. Manufacturing drawback needs either a general manufacturing ruling you operate under or a specific ruling you apply for, and that application is a step ahead of the claim itself, not part of it.

Before going further, put the numbers through the duty drawback calculator. Assembling years of entry records is real work, and it is worth knowing the order of magnitude of the refund first.

Step 2: assemble the import records

For every import entry you intend to claim against, you need the CBP Form 7501 entry summary, which shows the entry number, the HTS classification, the entered value and the duties, taxes and fees actually paid. The 7501 is the anchor of the claim — it is what proves there is duty to refund and how much.

Alongside it: the commercial invoice and packing list tying specific goods to that entry, and the entry number itself, which is the key you will use to link the import to the export in ACE. If your customs broker filed the entries, they hold these records; requesting five years of them in one go is a normal request and worth making early, because it is often the slowest part of the process.

At this stage, check the duty lines against drawback eligibility. Section 301 duties are generally claimable and often the largest component. Section 232 duties are not — the proclamations bar drawback on the additional 232 amount, while the MFN duty on the same entry remains claimable. IEEPA and reciprocal tariffs have generally been barred by the orders imposing them; verify the current position before including them.

Step 3: assemble the export or destruction evidence

For exports, the evidence is the bill of lading or air waybill, the commercial documents for the export sale, and where applicable the Electronic Export Information filed in AES with its Internal Transaction Number. Where the exporter is a party other than you, you need the export documentation plus a certification from that party assigning the drawback right to you — a common structure where goods are sold domestically and exported by the buyer.

For destruction, you need evidence that the destruction occurred under customs supervision and records certifying what was destroyed and when. Destruction is a full drawback trigger, not a lesser one, but it has to be arranged with CBP in advance rather than documented after the fact.

For rejected merchandise, you need evidence of the non-conformity, the shipment without consent, or the defect at time of import, alongside the export, destruction or return.

Step 4: build the linkage between import and export

This is the substance of the claim. Under direct identification, you demonstrate that the specific goods exported are the specific goods imported — traceable by lot, serial number or an accepted inventory accounting method for fungible merchandise. Under substitution, you demonstrate that the exported article and the imported article fall under the same 8-digit HTS subheading, with the special rule that applies where that subheading begins "other", and that the other statutory conditions are met.

For manufacturing claims, the linkage runs through the bill of materials and the production records: how much imported material was consumed in producing the exported article, on the basis set out in the ruling you are operating under.

Whichever route, the output is a claim schedule that pairs each export line with the import entry line it draws on, and states the duty attributable to it. This is what the filing software builds and what CBP reviews. It is also where the arithmetic constraints bite — substitution claims are limited by the lesser of the two duty rates, and total recovery is capped at 99% of the eligible duty paid.

Step 5: file CBP Form 7551 in ACE

Drawback claims are filed electronically in ACE, the Automated Commercial Environment. The drawback entry is CBP Form 7551, and it is transmitted through ABI-certified software by a party with a drawback filer code.

That means one of two routes in practice. Either you obtain filer access and file in your own name, which is worth doing only for a substantial recurring programme, or you file through a licensed customs broker or a drawback specialist who already has it. Either way the claim is filed at a single drawback office and covers the import entries and export lines on the schedule you built.

The filing itself carries the certifications: that the goods qualify, that the records supporting the claim exist and will be retained, and that no other claim has been made on the same duty. Those certifications are why the recordkeeping in the previous steps is not optional paperwork — they are the representation CBP relies on in paying before it reviews.

Step 6: decide on accelerated payment and the drawback bond

Without accelerated payment, the refund arrives when the claim liquidates. With it, CBP releases the refund shortly after accepting the claim, subject to later liquidation and to repayment if the claim is subsequently reduced.

Accelerated payment requires approved privileges and a drawback bond covering the amounts released early. Obtaining the bond is an underwriting step with a surety and an annual cost, so the decision is a cash-flow trade rather than a free improvement. For a one-off retrospective claim it is often not worth arranging; for a standing programme filing regularly, it usually is.

Step 7: what happens after filing

A filed claim is not a finished one. CBP reviews the claim and may issue requests for information — asking for the underlying entry summaries, export evidence, or the inventory records supporting the linkage. Responding well is a function of how the file was built, not of how the response is written.

The claim then liquidates, which is the point at which the refund becomes final. Liquidation can take considerable time and the timeline is not something the claimant controls; where accelerated payment was taken, the money is already with you and liquidation confirms or adjusts it.

Throughout, the retention obligation continues. Retaining the supporting records for three years from payment of the claim is the general baseline under Part 190, and because the filing window itself runs five years, the practical retention horizon is longer than most document policies assume.

Where to go next

To estimate the refund before starting, use the duty drawback calculator.

To make the claim as large as it legitimately can be, how to maximize duty drawback refunds covers drawback type selection, substitution matching, the five-year lookback and the errors that shrink claims.

To decide who files it, duty drawback companies and services describes the firms that do this work and how contingency and flat-fee models compare.

Drawback recovers duty already paid; it does nothing about the rate on your next entry. The tariff tracker logs duty-rate changes across the US, EU and UK schedules as they are detected, and Tariff Watch emails you when one lands on a code you import against.

Primary sources: 19 U.S.C. §1313, 19 CFR Part 190, and CBP's drawback guidance and CSMS messages. Filing decisions on your own facts belong with a licensed customs broker or drawback specialist.