The Complete Step-by-Step Guide to Filing Duty Drawback Claims in 2025

Filing duty drawback claims can be complex, but the financial rewards make it worthwhile for many businesses.

This guide walks through each step of filing a successful duty drawback claim in 2025, reflecting the latest regulations and best practices.

Drawback claims follow a structured process that demands meticulous documentation and adherence to specific timelines.

TFTEA modernized many aspects, but the process remains detail-oriented and compliance-focused.

Before starting the filing process, ensure you have:

Determine which drawback type applies to your situation and confirm eligibility. The main types include:

Each type carries specific eligibility criteria and documentation requirements. Consulting a drawback specialist helps pinpoint the right fit.

Comprehensive documentation is the foundation of a successful claim. Required documents typically include:

CBP Form 7501 (Entry Summary), commercial invoices, bills of lading or air waybills, proof of duty payment, and entry documentation with HTS classifications.

Bills of lading or air waybills, commercial invoices, shipper's export declarations or EEI filings, and proof of exportation such as onboard bills of lading or carrier receipts.

Notice of intent to destroy, CBP Form 7553, destruction certificates or reports, and evidence of CBP supervision or waiver.

Manufacturing records showing the use of imported materials, bills of materials or formulas, production reports, and inventory records.

Certificates of delivery, certificates of manufacture and delivery, lab analyses or product specifications for substitution, and waivers of prior notice if applicable.

Organize documents systematically—ideally electronically—to streamline filing and CBP reviews.

Manufacturing drawback and some complex substitution claims may require CBP rulings before filing.

These establish your process and the relationship between imported materials and exported products, detailing the process, materials, outputs, waste factors, and tracking methods.

Substitution claims under the older “commercially interchangeable” standard may require a ruling confirming equivalency.

Obtaining rulings typically involves preparing the application, submitting it to CBP, responding to follow-up requests, and waiting roughly 90–120 days.

Under TFTEA, many substitution claims now rely on 8-digit HTSUS classification, eliminating some interchangeability rulings.

Once documentation and rulings are in place, prepare and file the drawback claim.

Identify eligible imports and exports, calculate the duty amount, complete CBP Form 7551 (or ACE equivalent), and compile supporting documentation.

All claims file through ACE: log in, access the drawback module, enter claimant details, drawback type, import/export data, claimed amounts, and references to supporting documentation, upload files, then submit.

Requesting accelerated payment requires a separate drawback bond, a compliance history, and a properly completed claim, but can significantly improve cash flow.

CBP reviews filed claims and may request additional information or documentation.

Clarifications, supplemental documentation, evidence of export or destruction, and manufacturing or inventory records.

Track progress in ACE. Processing time depends on claim complexity, documentation completeness, CBP workload, and whether accelerated payment was requested. Standard claims take months; accelerated claims may fund within weeks.

If approved, CBP issues payment and expects thorough records for three years from payment date.

Electronic funds transfer, offsets against other customs obligations, or (less commonly) checks.

Maintain all drawback-related records for at least three years and keep them audit-ready.

CBP can verify or audit claims within the record-keeping period, reviewing documentation, transactions, manufacturing data, or even conducting site visits. Discrepancies can trigger repayment with interest and penalties.

Know the typical timeline to set realistic expectations:

Documentation gathering (2–4 weeks), obtaining rulings (3–4 months), and setting up ACE accounts and bonds (2–3 weeks).

Preparing the claim inside ACE typically takes one to two weeks, with initial validations in one to two days.

Initial CBP review (1–2 months), requests for information (2–4 weeks), and final decisions (1–3 months).

Accelerated payment can land within three to six weeks; standard payment often takes three to six months after filing.

Overall timelines range from roughly four months for straightforward accelerated claims to over a year for complex filings requiring rulings.

Even experienced claimants hit snags. Here are recurring pitfalls and solutions:

Pitfall: Missing or incomplete documentation causes delays and denials.

Solution: Implement comprehensive document management and use checklists to capture everything at import and export.

Pitfall: Filing after the five-year deadline results in automatic denial.

Solution: Track import dates, set reminders, and file on a regular cadence rather than waiting.

Pitfall: Wrong HTS codes invalidate substitution claims.

Solution: Partner with classification experts and obtain binding rulings for unclear products.

Pitfall: Failure to trace imports through to exports or destruction.

Solution: Use inventory systems that maintain the import-to-export link and document manufacturing usage.

Pitfall: Incorrect calculations reduce or derail claims.

Solution: Use specialized software or double-check math, and document methodologies—especially for complex manufacturing formulas.

Beyond the basics, several strategies can maximize drawback recovery:

Integrate drawback into day-to-day import/export processes: design inventory systems with tracking in mind, train procurement and logistics teams, and factor drawback potential into sourcing decisions.

Leverage TFTEA's 8-digit HTSUS standard by matching high-duty imports with exports, identifying all qualifying products, and applying the “lesser of” rule intentionally.

For unsellable merchandise, plan destruction under CBP supervision, consolidate events, document thoroughly, and ensure environmentally responsible methods.

Adopt specialized software, OCR, automation, and dashboards to digitize documentation and monitor drawback potential.

Professional providers help when internal expertise, capacity, or systems fall short.

Specialized services like Evana provide expert guidance, dedicated software, representation with CBP, and support during audits or verifications.

Success requires attention to detail, thorough documentation, and a systematic approach.

Whether managed in-house or with a partner, duty drawback can become a significant source of cost recovery and competitive advantage.