Duty drawback, in plain words.

Manufacturing and unused claims can trace the imported goods (direct identification) or use substitutes in the same 8-digit HTS subheading.^⁠[1]⁠[8]

• One designation per import line. A line cannot be split between direct-identification and substitution claims. The first accepted claim sets it.^⁠[3]
• Exports to Canada and Mexico. USMCA limits drawback on many goods to the lesser of the U.S. duty or the duty paid there. Goods exported in the same condition get full drawback. Unused-merchandise substitution claims generally can't count these exports, so they rest on the goods you imported.^{⁠[1]⁠[17]}
• Retail returns. Goods sold at retail and returned to you, for any reason, can qualify once you export or destroy them under CBP's rules; the return alone does not. Notice is due at least 5 working days before export and 7 working days before destruction.^{⁠[1]⁠[15]⁠[16]}
• Fungible inventory can be traced by FIFO, LIFO, low-to-high or average.^⁠[13]

• Records, when your customer exports: your records must trace the goods from your import to its export: parties, dates, entry and line numbers, quantities, duties and the 10-digit HTS number.^{⁠[5]⁠[13]}
• Successors can claim on a predecessor's imports.^⁠[1]
• Who signs: officers, partners, owners, employees with a power of attorney, or "a licensed customs broker with a power of attorney to sign the applicable drawback document"^⁠[13].
• Payment: by ACH since February 6, 2026. You need an ACE Portal account and the ACH Refund application, or a party you designate on CBP Form 4811.^⁠[6]
• Filing your own claim needs no license when you act solely on your own account, but it does need software authorized to file in ACE. Preparing claims for others is customs business and takes a broker license.^{⁠[18]⁠[3]⁠[19]}

In CBP's random sample of 375 claimants from 2007 to 2016, 41.3% were wholesalers, 29.3% manufacturers and 8.8% retailers. By our grouping, apparel, footwear and textile businesses were the largest group (18.7%), and no aerospace or defense manufacturer appeared.^⁠[9]

For every claim

• Import entry data: entry and line numbers, 10-digit HTS, duties paid, value and quantity.^⁠[3]
• Proof of export: a "bill of lading, air waybill, freight waybill, Canadian Customs manifest, and/or cargo manifest," official postal records, or records from an electronic export system CBP has approved. It must show the date, exporter, goods, quantity, Schedule B or HTS number and destination.^⁠[16]
• Electronic Export Information (EEI): Census provides your AES records through ACE Export Reports, and the export rules allow their use as proof of export for drawback.^{⁠[20]⁠[21]}
• Commercial invoices, plus transfer records if the goods changed hands.^{⁠[22]⁠[13]}

Certificates of delivery are gone. The 2018 Modernized Drawback rule eliminated CBP Form 7552, "allowing trade members to instead keep evidence of transfers in their records kept in the normal course of business"^⁠[24].

Exported without a notice? For unused goods, ask CBP in writing for retroactive approval. CBP answers within 90 days, and the procedure "may be used by a claimant only once, unless good cause is shown"^⁠[12]. So a five-year lookback on unused goods depends on past notices, a waiver or this one-time approval.

Sources for the table: 19 CFR Part 190, Subpart I.^⁠[23] Your broker can prepare these applications with you. The surety issues the bond.

The bond must be "in an amount sufficient to cover the estimated amount of drawback to be claimed during the term of the bond"^⁠[25]. You and the surety agree to "refund on demand the full amount of any overpayment, as determined on liquidation"^⁠[26]. Overpayments not repaid within 30 days after liquidation become delinquent.^⁠[25] We have not found a reliable published figure for bond premiums, so ask a surety for a quote before you apply.

• Filers reach ACE through ABI, CBP's electronic interface for certified brokers, importers and service bureaus.^⁠[27]
• A claim is complete when ACE accepts the drawback entry with the import data, any notices of intent and the evidence of export or destruction. A claim not complete within five years of import is considered abandoned, with extensions only for CBP-caused delay or a declared major disaster.^⁠[3]
• CBP's four drawback offices are in Chicago, Houston, New York and San Francisco. A broker with a national permit can file at any of them.^⁠[28]
• To dispute a liquidation, you file a protest under 19 CFR Part 174, generally within 180 days.^⁠[5]

A first claim takes longer. If you want accelerated payment and do not hold it, CBP has up to 90 days to answer, and the bond must be in place.^⁠[25]

The five-year limit, as dates. Imports from October to December 2021 pass the five-year limit between October and December 2026.^⁠[1]

Records outlast the claim. Claim records stay three years after the claim liquidates;^{⁠[13]⁠[31]} an older rule counts three years from payment, so keep them to the later date.^⁠[32] Export records stay five years from export.^⁠[33] Near the five-year limit, that can mean keeping import records eight years or more (our reading of the rules, not CBP's).

• January 16, 2026: CBP ruling H350722 found an unlicensed platform "impermissibly conducting customs business"; filing decisions belong to a licensed broker.^⁠[41]
• February 6, 2026: CBP pays all refunds, drawback included, by ACH.^⁠[6]
• May 7, 2026: CBP's refund-scam warning, CSMS #68569567.^⁠[42]
• June 24, 2026: de minimis, suspended since August 29, 2025, was suspended indefinitely except for international mail, and the exemption ends by statute on July 1, 2027. Low-value returns may now carry duty that drawback can return.^⁠[43]
• October 1, 2026: merchandise processing fee limits rose to $34.58 and $670.86; the 0.3464% rate is unchanged.^⁠[44]

Most IEEPA refunds go through CAPE, CBP's process for refunding IEEPA duty with interest. It returns 100% of the IEEPA duty on every unit; drawback returns up to 99% on exported units. After CAPE, drawback can still recover the other duties on what you exported, based on the final liquidated duties.^⁠[5]

CAPE is filed by the importer of record or its filing broker; refund firms work through one of them.

Third-party costs: a surety bond for accelerated payment, and your broker's filing fee if the provider's fee does not include it.

Terms worth checking: whether anything is due before CBP pays, and whether the refund lands in your own account; CBP pays the claimant or a party you name on Form 4811.^⁠[6] CBP's fraud bulletin lists "requests for personal or financial information" and "pressure to act quickly" among its warning signs.^⁠[42]

The answers tell you more than the provider's category. As of October 2026, drawback is offered by AI-first brokerages, refund agencies, consultancies and customs brokers working alone.