US Duty Drawback Eligibility Checklist (Free)

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10 critical items still open - these are the highest-risk gaps.

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Imports and duties paid

Imported merchandise entered for consumption with duties, taxes or fees paidCRITICALEntry numbers, entry dates and HTS classification retrieved for each import lineCRITICALImport date is within 5 years of the drawback claim filing dateCRITICALImporter of record identified and, if different from claimant, a valid assignment or certificate of delivery is in placeDuty amounts confirmed from the entry summary, including any additional trade-action dutiesConfirmed whether any duties paid carry a drawback restriction

Manufacture or use

Process identified: manufacture or production, unused merchandise, or rejected merchandiseCRITICALImported materials traceable into the exported article (direct identification) or eligible for substitutionCRITICALIf 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 unitWaste, scrap and by-products accounted for, with values where requiredFor unused merchandise, evidence that the goods were not used in the US before export

Export or destruction

Goods exported or destroyed under CBP supervision within the permitted time after importCRITICALExport proof available: AES/EEI record, bill of lading, airway bill, or other accepted evidenceCRITICALExport dates and quantities tie to the production or inventory recordsExports to Canada or Mexico supported by acceptable proof of exportConsider whether the exports are claimed under a free trade agreement rule that restricts drawback

Records and filing

Drawback specialist, broker or internal owner assigned and account in ACE confirmedCRITICALAccelerated payment bond considered if cash timing mattersClaim packet assembled: entries, production records, export proof, certificatesClaim filed electronically through CBP ACE within the 5 year limitCRITICALRecords kept for the required period after claim payment (generally 3 years)CRITICALERP can produce lot-to-entry and lot-to-export traceability reports on requestInternal sign-off by finance and trade compliance on each claim

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.

Import to export traceability review

Optional: we can look at whether your ERP links import entries to production lots and export shipments.

Optional. The tool and every export work without this. No spam.

How to use the checklist

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

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.

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

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.

Frequently Asked Questions

How long do I have to file a drawback claim?

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?

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?

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?

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.

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.

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US Duty Drawback Eligibility Checklist for Manufacturers