Claims can be filed up to five years from each import date.
New duties took effect around and after the lapse; some advisers call them replacement tariffs:
- Section 301, forced labor: in force July 24, 2026. Drawback-eligible.
- Section 301, Brazil: in force July 22, 2026, under a July 15 memorandum. Drawback-eligible.
- Section 338, Canada: 50% on dairy, alcoholic beverages and motor vehicles, in force August 22, 2026. Drawback-eligible.
- Section 232: pharmaceuticals (eligible), drones (manufacturing only) and polysilicon (manufacturing only, from December 4, 2026).
Why they matter for drawback: each sits on its own Chapter 99 line with its own drawback rule, and one entry can carry several.
A claim has to split every duty line by program before it can match exports.
The agent does that split on each CBP 7501, and your broker reviews it.
If you exported goods imported between February 24 and July 24, 2026, those entries may carry the surcharge plus other duty. Your entries decide.
- Proclamation 11012[1]
- CBP CSMS #67844987, Feb 23, 2026[2]
- CBP CSMS #69567203, Aug 18, 2026[3]
- CBP CSMS #69302472, Jul 21, 2026[4]
- CBP CSMS #69606660, Aug 21, 2026[5]
- Proclamations 11020, 11052 and 11055[6][7][8]
- 19 U.S.C. 1313(r)[9]
- What is the current status of the Section 122 tariffs implemented following the IEEPA Supreme Court decision?
- What new tariffs are in place after the lapse of Section 122 authority?
- What are replacement tariffs and why do they matter?
Written by the NexQloud Drawback team from the primary sources linked on this page.
Not legal advice. NexQloud Drawback is not a government agency.
NexQloud Drawback is software used by licensed customs brokers.
