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.

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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.