The Complete Duty Drawback Checklist for eCommerce Businesses
Ensure you don't miss any steps in the duty drawback process with our comprehensive checklist tailored specifically for eCommerce businesses importing and exporting goods.
Evana Team
Duty Drawback Specialists
The Complete Duty Drawback Checklist for eCommerce Businesses
For eCommerce businesses that import products and then export them internationally or destroy returned merchandise, duty drawbacks represent a significant financial opportunity.
CBP estimates over $15 billion in eligible drawbacks go unclaimed each year, translating to 1.3%–5.9% of annual revenue for the average importer—money that could return to your bottom line.
This checklist keeps the process organized so you are not leaving refunds on the table.
Pre-Qualification Checklist: Do You Qualify?
Verify these fundamentals before diving into documentation:
- •Import confirmation: Duties, taxes, or fees were paid on imported merchandise, with HTS classifications documented.
- •Qualifying activities: You exported the same merchandise unused, used imports to manufacture exported goods, or destroyed merchandise under customs supervision.
- •Timeframe verification: All relevant activities occurred within the five-year statutory lookback period.
- •Value confirmation: Potential recovery exceeds the cost of pursuing claims (usually meaningful above $250k in annual imports).
Documentation Gathering Checklist
Documentation issues cause approximately 58% of rejected claims—ensure these records are organized:
Import Documentation
Maintain complete copies of:
- •Entry summaries (CBP Form 7501) proving duties were paid.
- •Commercial invoices detailing purchased goods.
- •Bills of lading or air waybills documenting transport.
- •Proof of duty payment records.
- •HTS classification records for imported items.
- •Detailed product descriptions for clear identification.
Export Documentation
Capture the following to verify exports:
- •Export bills of lading or air waybills showing goods left the country.
- •Commercial invoices for exports detailing shipments.
- •Shipper's Export Declarations or EEI filings when available.
- •eCommerce platform export records for international sales.
- •Proof of delivery to international destinations (tracking or receipts).
Destruction Documentation (If Applicable)
For destruction-based claims, assemble:
- •Notice of intent to export or destroy filed with CBP ahead of time.
- •Evidence of destruction such as photos, videos, or certificates.
- •Customs supervision documentation proving CBP presence or approval.
Linking Documentation
These records tie imports to exports or destruction:
- •Inventory management records tracing goods from import to export.
- •Lot, batch, or serial number tracking when applicable.
- •Manufacturing records showing how imports were incorporated into exported goods.
eCommerce-Specific Documentation Requirements
Online sellers have a 35% lower success rate due to documentation gaps—address these areas:
For Direct-to-Consumer International Sales
Compile platform export reports, order-level detail linking imported SKUs to international orders, carrier tracking data, and SKU/UPC identifiers that link imports to exports.
For Returned or Destroyed Merchandise
Maintain return authorization records, destruction documentation, and proof the destroyed items match the imported goods on which duties were paid.
Claim Preparation Checklist
Proper preparation improves approval rates by 82%:
- 1.Review eligibility requirements for your drawback type (19 CFR part 190).
- 2.Organize all documentation chronologically.
- 3.Map import entries to export or destruction records, align HTS codes, and link duties paid to claimed amounts.
- 4.Calculate the drawback amount, accounting for duty rates, MPF, HMF, and any HTS-based exclusions.
- 5.Prepare CBP Form 7551 (Drawback Entry) with complete, accurate data.
- 6.If filing via ACE, ensure all data elements are properly formatted for electronic submission.
Submission and Follow-up Checklist
After preparing your claim, follow these steps:
- 1.Submit the claim through ACE or a licensed customs broker.
- 2.Maintain copies of every submitted document.
- 3.Record the assigned claim number for tracking.
- 4.Set reminders to follow up if no response within 90 days.
- 5.Respond promptly to any CBP requests for additional information.
- 6.If rejected, analyze the reasons and plan resubmission.
- 7.Upon approval, verify the refund amount received.
- 8.Maintain all documentation for at least three years post-payment.
Common Pitfalls for eCommerce Businesses
Rejected claims often stem from:
- •Insufficient linkage documentation between imports and exports.
- •Incomplete platform export records lacking required detail.
- •Improper destruction documentation that fails CBP standards.
- •Missing proof of duty payment.
- •Timeframe violations outside the five-year period.
- •Inconsistent product descriptions across import and export files.
The Resource Investment Reality
Understand the commitment required:
- •Time investment: First claims often demand 120–180 hours according to a 2023 trade compliance survey.
- •Expertise requirements: Success requires customs regulation, trade law, and accounting knowledge.
- •Software needs: Specialized tools are often necessary to track imports, exports, and documentation.
- •Ongoing commitment: Filing regularly maximizes recovery; one-off claims leave money behind.
The Partner Alternative: Specialized Duty Drawback Services
Many eCommerce businesses turn to providers like Evana for these benefits:
- •Reduced internal resource requirements—client time often drops to 2–4 hours.
- •Higher recovery rates, averaging 30–40% more due to expert identification of opportunities.
- •Faster processing thanks to established CBP relationships and precise documentation.
- •Risk mitigation via contingency fee structures with no upfront cost.
- •Technology advantages from purpose-built software that automates documentation and matching.
Next Steps: Your Duty Drawback Action Plan
To determine the right approach:
- 1.Assess qualification using the pre-qualification checklist.
- 2.Estimate recovery potential by calculating duties paid over the past five years.
- 3.Evaluate internal resources and expertise.
- 4.Consider specialized solutions—partners often deliver the highest ROI.
- 5.Implement ongoing tracking processes regardless of who files the claims.
Duty drawback refunds can reach up to 5.9% of annual revenue for qualifying eCommerce businesses—too significant to ignore.
By following this checklist, you'll be positioned to recover funds that rightfully belong back in your business.
To learn how Evana can manage the process with minimal time investment and no upfront cost, contact our duty drawback specialists for a free assessment.
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