U.S. duty drawback: Maximize your refund potential

Duty drawback is a U.S. Customs Border Protection (CBP)-administered program that refunds up to 99% of eligible import duties, certain fees, and internal revenue taxes paid on goods that are later exported from the United States, used in the manufacture of an exported finished product, or destroyed under CBP supervision.

Companies import goods and pay duties, then export or destroy those goods (or qualifying substitutes). By linking import and export records, companies can file a claim with U.S. Customs and receive a refund of most of the drawback-eligible duties paid.

Any company that has the legal right to claim drawback while the goods are in the United States may be eligible. This typically includes importers, exporters, manufacturers, and distributors.

A company does not need to be the original importer to file a claim; as long as proper documentation is in place to transfer drawback rights, they may still qualify. While the right to drawback generally accrues to the exporter of record, that right may also be transferred to another party through proper documentation.

There are many types of duties or fees eligible for a drawback refund, including: 

• IRS taxes 
• Section 301 duties
• Section 122 duties
• Voluntary tenders
• Ordinary customs duties
• Harbor maintenance fees (HMF)
• Merchandise processing fees (MPF)
• Section 232 duties on the following: 
  • Timber
  • Lumber
  • Bus parts
  • Truck parts
  • Automobile parts
  • Wooden furniture

Generally, it’s possible to file a drawback claim up to five years from the date of import to the date of claim submission. This allows companies to recover duties on qualifying historical transactions.

Companies that import products and later export them, or export similar or substituted products, likely have eligibility. A structured review of trade data can confirm this.

Section 301 duties are eligible for drawback and are a common source of significant refunds for many importers.

Section 232 duties have more limited eligibility. Duties on steel, aluminum, and copper are not eligible for drawback. However, certain downstream products, such as lumber, timber, wooden furniture, automobile parts, truck parts, and bus parts, may still qualify, depending on how the duties were assessed.

Because eligibility can vary by product and duty type, a detailed review is often required to confirm what can be recovered.

Yes. The reciprocal duties imposed under International Emergency Economic Powers Act (IEEPA) are eligible for drawback.

However, recent legal developments have resulted in IEEPA duties being deemed unlawful, and CBP is issuing 100% refunds with interest through its newly established Consolidated Administration and Processing of Entries (CAPE) process.

Because of this, consider pursuing IEEPA-related refunds through the CAPE process via your customs broker, rather than through traditional drawback filings, to ensure full recovery.

Yes. In many cases, companies can claim drawback with proper documentation showing the transfer of drawback rights from the importer.

Typical documentation for duty drawback includes:

• Purchase orders
• Commercial invoices
• Bills of lading/export records
• Proof of export or destruction
• Import entry summaries (CBP 7501)
• Inventory or manufacturing records (if applicable)

The process for filing a duty drawback claim includes identifying eligible imports/exports, linking the data, preparing the claim, submitting it to CBP, and responding to any follow-up requests until the drawback claim is liquidated.

Timelines can vary, but many claimants take advantage of U.S. Customs’ accelerated payment program, which allows approved claims to be paid via ACH within a few weeks of submission.

For companies not using accelerated payment, refunds may take longer depending on claim complexity and CBP review times.

Key data for a duty drawback claim includes import entry details, duty payments, export shipment records, product classifications (HTS), and supporting commercial documentation.

For claims involving manufacturing, kitting, or assembled goods, bills of materials (BOMs) may also be required to demonstrate how imported components are incorporated into or associated with the exported products.

Refund amounts vary by company, but organizations with steady import and export activity often recover hundreds of thousands to millions of dollars annually.

A simple way to estimate potential recovery is:
Duty paid (on eligible imports) × % of those goods exported × 0.99

For example:
If a company paid $1,000,000 in eligible duties and exported 60% of those goods:
$1,000,000 × 0.60 × 0.99 = $594,000 potential refund

This is a high-level estimate, and actual recovery may vary based on eligibility rules, data quality, and claim structure, but it provides a quick way to assess whether drawback is worth exploring.

For companies with consistent trade flows, drawback can provide a meaningful cost reduction and margin improvement, often outweighing the administrative effort required.

C.H. Robinson helps global organizations with every step of the drawback process: 

1. Identifying eligible opportunities
2. Gathering and structuring data
3. Preparing and filing claims
4. Managing the process through approval

This level of support helps reduce complexity and improve recovery outcomes.

C.H. Robinson combines deep customs expertise, scalable technology, and supply chain insight to uncover opportunities others may miss and streamline the entire drawback process.

Using our Lean AI model, C.H. Robinson efficiently analyzes large volumes of trade data to identify eligible transactions, improve accuracy, and accelerate claim preparation while keeping processes cost-effective and transparent.

The C.H. Robinson drawback team is built with seasoned drawback professionals, bringing years of hands-on experience navigating complex regulatory requirements and delivering consistent results.

Getting started begins with an initial assessment of your import/export data to identify potential refunds. From there, C.H. Robinson can guide you through onboarding and begin recovering duties.