AI duty drawback: what AI does and what a broker decides

In a 2019 survey of large importers:

• Five of the nine companies that don't claim drawback and gave a reason (56%) said it is too complex.^⁠[4]
• Among companies that do claim it, 62% found getting import and export data electronically moderately to extremely challenging.^⁠[4]

A drawback file mixes entry summaries (CBP 7501), invoices, packing lists, transport documents, export records and sometimes bills of materials.

The rules say what an invoice must show, not what it must look like.^⁠[5]

A well-built system uses language models to:

• Read scans and PDFs in many layouts.
• Extract fields into a fixed schema: entry numbers, HTS codes, quantities, values, duties and export dates.
• Match an export to the import it came from when part numbers, descriptions or units differ between documents.
• Cross-check quantities across the invoice, the packing list and the 7501.
• Flag what is missing or unclear, with a reason, instead of guessing.

An agent adds planning: it takes stock of the file, asks for missing documents, runs its tools and checks its work before a person sees it.

That is what "agentic" should mean.

The rules are exact:

• Drawback is up to 99% of the duties, taxes and fees paid on the matched quantity.^⁠[3]⁠[8]

• Duty is split by program. Section 301 duties are drawback-eligible.^⁠[9]

  Drawback on Section 232 duties depends on the program. IEEPA duty goes to CBP's CAPE process first.

• Merchandise processing fees and harbor maintenance tax are apportioned to the matched lines.^{⁠[8]⁠[10]}
• Substitution claims are capped by the statute's lesser-of rule.^⁠[3]
• Each claim must be filed within five years of import.^⁠[3]
• Totals are re-footed to each 7501, to the cent.

A worked line from our demonstration file (synthetic data, not a client result):^⁠[6]

In ruling H350722 (January 16, 2026), CBP looked at an unlicensed company whose software pulled entry data from shipping documents.^⁠[1]

Three points apply to any AI drawback tool:

1. Software that identifies entry data is doing customs business.

   An OCR tool that identifies the information for an entry "prepares parts of the data appearing on an entry," CBP wrote.

2. A licensed person decides.

   "A tool does not constitute a 'person'," so the decision on classification "or any other information needed to make entry, must be made by a duly licensed customs broker."

3. The power of attorney runs direct.

   A broker must obtain it "directly from" the importer of record or drawback claimant, and the company "may not act as an intermediary."^⁠[12]

CBP also cautioned that a fee "tied to the entry filed by the broker" may violate 19 CFR 111.36(b).

It recalled an earlier case in which a disclaimer did not "absolve" a company.^⁠[13]

The ruling dealt with import entries. Drawback falls under the same definition of customs business, so we apply it to claims too.

In practice the broker decides whether each line is claimable, which drawback type applies, how each import line is designated and what goes in the claim.

The broker supervises the work^⁠[14] and files in ACE as entry type 47.

Importers and exporters may also file on their own account without a license.^⁠[15]

"More recovered" claims need the same questions: more than what, measured how, by whom?

The FTC applies the same test.

Its August 2025 final order bars Workado, maker of an AI content detector, from claiming the product works without "competent and reliable evidence to support the claim at the time it is made."^⁠[16]

Our figures follow these rules, so we make no accuracy claim.

In a typical AI system, documents pass through five places.

Ask any provider about each:

• Which model reads the documents? Does a third-party AI provider receive them?
• Are they ever used to train a model?
• How long are they kept?
• Who can read them, and is every access logged?
• Where are they processed?
• What can you check, beyond a promise?

1. Which licensed customs broker files? Get the name and license number.
2. Can your own broker file instead?
3. Does a licensed broker review every line before filing, and is each approval logged?
4. Does your power of attorney run directly between you and the broker?
5. Does every claim line name its import entry, its export and its source document?
6. Do you get a line-level CSV you can re-foot yourself?
7. Does every accuracy figure come with its denominator, test set and date?
8. Who can read your documents, and what can the provider show you to prove it?
9. How are IEEPA duties handled? CAPE excludes entries that are the subject of a drawback claim, and CBP recommends filing CAPE first.^⁠[18]
10. Are fees published, charged on principal only and due after CBP pays? Is there any retainer, advance, assignment of your refund or Form 4811 designation?
11. Does anyone promise when CBP will pay? With accelerated payment, CBP can pay before the claim is final.^⁠[19]
12. Does anyone ask for your ACE login or bank details? CBP lists such requests among its fraud warning signs.^⁠[20] We never ask for them.