Rule changes

Regulatory updates

Rule changes that affect duty drawback and tariff refunds, newest first. Each one carries its date and a link to its source.

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Rule changes that affect drawback

When a rule changes again, we add it to the top of this list.

  1. · Rates and fees

    Merchandise processing fee limits rise for fiscal 2027

    From October 1, 2026, the formal-entry fee runs from $34.58 to $670.86, at an unchanged 0.3464% of value.

    Source: Federal Register 2026-15530⁠[1]

  2. · Rates and fees

    Interest on duty refunds for the fourth quarter

    Interest on customs duty refunds is 6% a year on corporate overpayments and 7% on non-corporate ones, from October 1 to December 31, 2026.

    Source: Federal Register 2026-19292⁠[2]

  3. · Section 232

    Section 232 pharmaceutical duties apply to all companies

    From September 29, 2026, Section 232 duties on patented pharmaceuticals apply to companies outside Annex III too; drawback is available.

    Source: Federal Register 2026-06956⁠[4]

  4. · CAPE and IEEPA

    CAPE Phase 3 scheduled for court plaintiffs

    CAPE Phase 3 was scheduled to open October 6, 2026, for Court of International Trade plaintiffs only (as of September 17, 2026).

    Source: Thompson Hine, on CBP's CAPE guidance⁠[5]

  5. · Section 338

    Section 338 duty scope changes

    Proclamation 11065 changed the scope of the Section 338 duties on Canadian goods from September 15, 2026.

    Source: Federal Register 2026-18839⁠[3]

  6. · Section 232

    Section 232 duties on drones begin

    Duties on drones and their components apply from September 3, 2026, and only manufacturing drawback is available, with partner-country conditions.

    Source: Federal Register 2026-16979⁠[6]

  7. · Section 338

    Section 338 duties on Canada begin

    A 50% duty took effect on certain Canadian alcoholic beverages, dairy products and motor vehicles; CBP says it "is subject to drawback."

    Sources: Federal Register 2026-17294⁠[3]; CBP CSMS #69606660⁠[7]

  8. · Section 301

    2026 Section 301 duties confirmed drawback-eligible

    CBP corrected ACE to allow drawback on the 2026 Section 301 headings for Brazil and forced labor, which it says "are drawback eligible."

    Source: CBP CSMS #69567203⁠[8]

  9. · Section 201

    Section 201 quartz safeguard begins

    A four-year tariff-rate quota on quartz surface products took effect; the proclamation does not mention drawback, and we found no CBP guidance.

    Source: Federal Register 2026-15975⁠[9]

  10. · Section 301

    ACE blocks drawback on new Section 301 headings

    CBP announced that ACE validations deployed August 12, 2026 disallowed drawback on the 2026 Section 301 headings for Brazil and forced labor.

    Source: CBP CSMS #69535943⁠[10]

  11. · Section 232

    Section 232 duties on polysilicon proclaimed

    Duties on polysilicon and its derivatives apply from December 4, 2026, with manufacturing drawback only, for content entirely from a partner country.

    Source: Federal Register 2026-16400⁠[11]

  12. · Section 232

    Section 232 pharmaceutical duties begin

    Duties on patented pharmaceuticals apply from July 31, 2026 to companies in Annex III, and the proclamation says "Drawback shall be available."

    Source: Federal Register 2026-06956⁠[4]

  13. · Section 122

    Section 122 surcharge ends

    The 10% surcharge expired after 150 days; it applied to entries from February 24 to July 24, 2026.

    Source: Federal Register 2026-03824⁠[12]

  14. · Section 301

    Section 301 forced-labor duties begin

    Duties of 10% or 12.5% on goods from 60 economies took effect July 24, 2026; goods under Section 232 are exempt.

    Source: Federal Register 2026-15274⁠[13]

  15. · Section 301

    Section 301 duty on Brazil begins

    A 25% duty under heading 9903.05.01 applies to certain products of Brazil entered from July 22, 2026.

    Source: CBP CSMS #69302472⁠[14]

  16. · Section 338

    Section 338 duties on Canada proclaimed

    Proclamations 11046 to 11048 set additional duties on certain Canadian alcoholic beverages, dairy products and motor vehicles.

    Source: Federal Register 2026-14997⁠[3]

  17. · Section 232

    No Section 232 tariff on commercial aircraft

    Proclamation 11040 opened negotiations on commercial aircraft, jet engines and parts and imposed no tariff.

    Source: Federal Register 2026-14334⁠[15]

  18. · CAPE and IEEPA

    CAPE Phase 2 adds reconciliation entries

    Phase 2 of CAPE opened June 29, 2026, adding entries flagged for reconciliation under the same 80-day limit.

    Source: Thompson Hine, on CBP's CAPE guidance⁠[16]

  19. · CAPE and IEEPA

    CBP warns of IEEPA refund scams

    CBP's warning signs include unknown parties offering to file, requests for bank details or passwords, and pressure to act.

    Source: CBP CSMS #68569567⁠[17]

  20. · Section 232

    Section 232 metals restructured

    Annex I-A steel, aluminum and copper articles get no drawback; partner-country Annex I-B and III articles get manufacturing drawback only, with origin conditions.

    Source: Federal Register 2026-06960⁠[19]

  21. · Section 122

    Section 122 surcharge begins

    A 10% surcharge applies to entries for 150 days, and CBP says "Drawback is available with respect to the additional duties imposed."

    Sources: Federal Register 2026-03824⁠[12]; CBP CSMS #67844987⁠[20]

  22. · Drawback rules

    CBP pays refunds by ACH

    CBP pays refunds by ACH, drawback included; you need an ACE Portal account and the ACH Refund application, or a Form 4811 designee.

    Source: Federal Register 2025-24171⁠[23]

  23. · Section 232

    Section 232 semiconductor duties, with no drawback

    Proclamation 11002 imposed Section 232 duties on semiconductors, and no drawback is available on them.

    Source: Federal Register 2026-01052⁠[24]

  24. · Section 232

    Auto and truck parts: manufacturing drawback only

    Section 232 duties on auto parts and medium- and heavy-duty truck parts allow "only manufacturing drawback claims," and no other drawback.

    Source: Federal Register 2025-19639⁠[25]

  25. · Section 232

    Section 232 timber and lumber duties begin

    Duties on timber, lumber and their derivative products apply from October 14, 2025, and the proclamation says "Drawback shall be available."

    Source: Federal Register 2025-19482⁠[26]

  26. · CAPE and IEEPA

    Reciprocal IEEPA duties drawback-eligible

    CBP said "Drawback is available" on the reciprocal IEEPA duties; those duties ended February 20, 2026, and refunds now go through CAPE.

    Source: CBP CSMS #64680374⁠[27]

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IEEPA refunds

Got your IEEPA refund? Drawback is the one that repeats.

We check every entry for CAPE first, the order CBP recommends.⁠[18] Drawback can recur every year.

Which tariffs qualify?

Section 301 duties, the Section 122 surcharge and the Section 338 duties on Canada all qualify.⁠[28]⁠[29]⁠[7]

How CAPE and drawback fit together

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What is duty drawback?

A refund of up to 99% of the duties, taxes and fees you paid on imports that you later export or destroy, or that went into products you export.⁠[30] It works in any industry.

When can I start?

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What will you need from me?

One quarter of records to start: entry summaries, invoices, packing lists, shipping documents, and export, return or destruction records.

How long until CBP pays?

With accelerated payment, CBP can pay before the claim is final. Its only published timing, from December 2018: processing "will generally take place within 3 weeks of the claim resubmission date."⁠[31]

Can I use my own customs broker?

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What if CBP pays less than claimed?

The fee follows what CBP actually pays. If CBP later recovers part of a payment, the fee is reduced to match.

Do you file CAPE claims?

No. We check every entry for CAPE first and flag what belongs there. You or your broker files CAPE. Refund firms work through one of you.

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