Duty drawback is the largest overlooked working-capital lever in US importing. The program is authorized under 19 USC 1313, refunds up to 99% of duties, taxes, and fees — including Section 301 duties — and applies to a 5-year lookback from the date of import.
If you import inputs and export finished goods, if you export overseas or sell into duty-free zones, or if any of your imports arrived defective and were destroyed — you likely have unclaimed drawback sitting in your ACE data right now.
Who it fits: Distributors and importers who resell or export imported goods in the same condition they arrived.
Applies when imported merchandise is exported or destroyed under CBP supervision without being used commercially in the US. Includes both direct identification — same imported goods exported — and substitution, where commercially interchangeable goods (same 8-digit HTSUS) can be substituted within a 5-year window.
Who it fits: Manufacturers that import raw materials or components and export finished goods.
Refunds duties on imported inputs used to produce goods that are subsequently exported. Substitution manufacturing drawback (1313(b)) allows commercially interchangeable substitutes to be used, dramatically simplifying record-keeping for chemical, textile, and electronics manufacturers.
Who it fits: Importers of goods that arrived defective, damaged, or non-conforming to sample.
Full duty refund on imported merchandise that does not conform to sample or specification, was shipped without consent, or was determined to be defective at time of import. Must be exported or destroyed under CBP supervision within 5 years of import.
Pull ACE entry data for the last 5 years. Map imports to potential exports or destructions. Quantify the recoverable duty pool — including any Section 301 exposure — before committing to program build-out.
Choose the drawback type(s) that fit your operations. File the required rulings, notices of intent to export, or manufacturing drawback rulings with CBP. Set up SKU-level mapping between import entries and export shipments.
Compile the first claim covering the 5-year lookback. File electronically through ACE. Concurrent applications for accelerated payment privileges where volume justifies.
CBP processes and pays. Ongoing quarterly filings capture new activity. Program is largely automated after year one.
We work on contingency — a percentage of the recovered refund, agreed up front. You pay nothing during discovery, program design, or filing. If CBP does not approve the claim, you owe nothing.
For high-volume importers, we also offer a flat quarterly retainer that typically comes in below contingency after year one, once the program is running on autopilot.
No commitment. If the recoverable pool is too small to justify a program, we'll tell you — most consultants won't.