# US Duty Drawback Eligibility Checklist for Manufacturers > Source: https://netray.co/tools/us-duty-drawback-eligibility-checklist > Publisher: Netray (netray.co), AI and integration engineering for ERP and manufacturing systems. > Section: Free Tools ## Short answer Work through import, manufacturing, export and record keeping questions to see if you can reclaim duties paid on imported materials that are later exported. ## Category compliance-legal ## Region United States ## Industry Manufacturing ## Audience - Customs compliance manager - Trade compliance - Controller ## Tool **Kind:** checklist **Groups:** #### Imports and duties paid **Items:** **Text:** Imported merchandise entered for consumption with duties, taxes or fees paid **Critical:** true **Text:** Entry numbers, entry dates and HTS classification retrieved for each import line **Critical:** true **Text:** Import date is within 5 years of the drawback claim filing date **Critical:** true Importer of record identified and, if different from claimant, a valid assignment or certificate of delivery is in place Duty amounts confirmed from the entry summary, including any additional trade-action duties Confirmed whether any duties paid carry a drawback restriction #### Manufacture or use **Items:** **Text:** Process identified: manufacture or production, unused merchandise, or rejected merchandise **Critical:** true **Text:** Imported materials traceable into the exported article (direct identification) or eligible for substitution **Critical:** true If substituting, imported and substituted goods share the same 8 digit HTS subheading (or other permitted standard) Bill of materials and yield data show quantities of imported material used per exported unit Waste, scrap and by-products accounted for, with values where required For unused merchandise, evidence that the goods were not used in the US before export #### Export or destruction **Items:** **Text:** Goods exported or destroyed under CBP supervision within the permitted time after import **Critical:** true **Text:** Export proof available: AES/EEI record, bill of lading, airway bill, or other accepted evidence **Critical:** true Export dates and quantities tie to the production or inventory records Exports to Canada or Mexico supported by acceptable proof of export Consider whether the exports are claimed under a free trade agreement rule that restricts drawback #### Records and filing **Items:** **Text:** Drawback specialist, broker or internal owner assigned and account in ACE confirmed **Critical:** true Accelerated payment bond considered if cash timing matters Claim packet assembled: entries, production records, export proof, certificates **Text:** Claim filed electronically through CBP ACE within the 5 year limit **Critical:** true **Text:** Records kept for the required period after claim payment (generally 3 years) **Critical:** true ERP can produce lot-to-entry and lot-to-export traceability reports on request Internal sign-off by finance and trade compliance on each claim **Scoring Note:** Critical items must all be checked before filing. If a critical item is missing, fix it or consult a licensed customs broker or drawback specialist before submitting a claim. ## Content **Intro:** Duty drawback lets importers recover most of the duties, taxes and fees paid on imported merchandise when that merchandise, or a qualifying substitute, is later exported or destroyed. This checklist walks through the conditions a plant needs to meet before filing. **Sections:** #### How to use the checklist **Body:** Work through each group in order: imports, manufacture or use, export or destruction, then records and filing. Check each item as you confirm it with documents, not memory. The critical items are the ones that, if absent, normally make a claim fail. Use the results to decide whether to file in-house, hire a specialist, or skip drawback for a given product line. #### What the law looks for **Body:** Drawback under 19 U.S.C. 1313 comes in several forms, and current rules allow up to 99 percent of duties, taxes and fees to be refunded. The three themes are the same across them: duties were paid, the goods or substitutes went through a qualifying process, and they left the country within the time limits. **Bullets:** - Manufacturing drawback: imported material used in goods later exported - Unused merchandise drawback: imported goods exported without use - Rejected merchandise: goods returned or exported after rejection - Substitution: allowed when classification standards are met #### Common mistakes **Body:** Plants lose claims over weak traceability: they cannot tie a specific import entry to a specific export shipment. The second common mistake is missing the 5 year filing window on older entries. A third is ignoring duty types: some trade-action duties have special drawback treatment, so confirm what is and is not recoverable for each tariff line. **Cta:** If lot traceability from import entry to export shipment is the gap, Netray can help your ERP produce that report without changing how the plant runs. **Faq:** #### How long do I have to file a drawback claim? **Answer:** Generally within 5 years of the date of importation of the merchandise. Claims for older entries are lost, which is why many companies review their export history yearly. #### Can I claim drawback if I did not import the goods myself? **Answer:** Possibly, if the importer of record transfers the right through a proper certificate of delivery or assignment. Without valid paperwork from the importer, the claimant has no right to the refund. #### Do I need a customs broker? **Answer:** Not legally, but drawback is document intensive. Many manufacturers use a specialist because errors in the claim can delay payment. You remain responsible for the records either way. #### Does drawback apply to all duties? **Answer:** Most ordinary duties qualify, but some additional trade-action duties have restrictions, and certain fees do not qualify. Check the current CBP guidance for each tariff line before counting on a refund. ## Search terms duty drawback checklist, us duty drawback eligibility, 19 usc 1313 drawback, manufacturing drawback requirements, unused merchandise drawback, substitution drawback same 8 digit hts, drawback claim records, recover import duties on exports --- Talk to an engineer: https://netray.co/contact?intent=erp_ai | Machine catalog: https://netray.co/agent/catalog.json