Field Instrument · PDF · Free
Denial-Proof Document Checklist
Every document CBP, drawback specialists, FTZ reviewers, and refund-advance underwriters expect to see — before you file, apply, or request an advance. Missing any one of these is the most common reason claims are denied and funding is declined.
What's inside
- · Entry & import records
- · Tariff refund / protest evidence
- · Duty drawback documentation
- · FTZ activation & admission
- · First Sale for Export
- · Refund-advance underwriting file
- · Cross-cutting compliance
- · Filing deadlines at a glance
1. Entry & Import Records
- CBP Form 7501 for every entry in the claim period
- ACE Entry Summary — full detail, not the summary view
- Commercial invoices matching each entry line
- Packing lists and ocean/air bills of lading
- Broker classification worksheet and duty-paid proof
- Liquidation notice or bulletin notice date per entry
2. Tariff Refund / Protest
- Written basis for refund (misclassification, valuation, origin, 301 exclusion)
- Supporting CBP ruling, CIT case citation, or exclusion grant
- Revised HTS with technical justification
- Country-of-origin evidence: mill certs, factory affidavits
- Protest filed within 180 days of liquidation
- PSC filed within 300 days of entry (pre-liquidation)
3. Duty Drawback
- Import 7501s with duty paid and export/destruction proof
- SKU-level match between imported and exported goods
- Manufacturing records for substitution/manufacturing drawback
- Chain of custody covering the 5-year window
- Drawback privileges: accelerated payment, waiver of prior notice
4. Foreign Trade Zone (FTZ)
- FTZ Board approval letter and CBP activation approval
- Operator's bond and procedures manual
- Inventory control system (ICRS) documented and tested
- CBP Form 214 admission records for each shipment
- Zone status elected per lot; weekly entry procedure documented
5. First Sale for Export
- Factory (first sale) invoice separate from middleman invoice
- Evidence of arm's-length factory ↔ middleman transaction
- Proof goods were destined for US export at first sale
- Payment trail: factory → middleman → importer
6. Refund-Advance / Drawback Financing
- Claim summary with entry-level detail
- Broker letter granting the lender ACE read access
- Filed protest / PSC / drawback claim number and confirmation
- Prior recovery history and CBP aging schedule
- Company financials, bank statements, A/R aging
- Assignment of proceeds language reviewed by counsel
7. Cross-Cutting Compliance
- Reasonable Care file with written procedures
- Recordkeeping meets 19 CFR 163 (5-year retention)
- Power of Attorney on file with broker and filers
- Prior disclosure filed for known errors before CBP finds them
- Internal audit of top HTS codes and suppliers in last 12 months
Educational only. Not legal, tax, or customs advice. Confirm current CBP guidance before filing.