Definition
A certificate of delivery (CBP Form 7552) recorded each transfer of imported merchandise, or of an article made from it, to the next party in the chain, and assigned that party the right to claim drawback (former 19 CFR 191.10). TFTEA ended the requirement: for claims under the modernized rules, ordinary business records show the transfer instead (19 U.S.C. 1313(b)(2)(C), (c)(3) and (j)(2); 19 CFR 190.10). CBP no longer requests or accepts Form 7552 on current claims.
Also known as: certificates of delivery, CBP Form 7552
What was a certificate of delivery?
When the importer and the exporter were different companies, the right to drawback had to follow the goods. Each transfer was documented on a certificate of delivery (CBP Form 7552), which identified the goods as carrying a potential drawback right and assigned it to the recipient; manufactured articles used a separate certificate of manufacture and delivery (former 19 CFR 191.10 and 191.24). The recipient kept the certificate and produced it when CBP asked.
When were certificates of delivery eliminated?
TFTEA, signed on February 24, 2016, provides that no additional certificates of transfer are required. It applies to claims filed on or after February 24, 2018, and the option to file under the old rules ended after February 23, 2019. CBP's final rule (CBP Dec. 18-15, 83 FR 64942, December 18, 2018) said it would completely eliminate Form 7552 and let traders keep evidence of transfers in their normal business records. A Federal Register notice from November 24, 2025 is sometimes cited as the end of certificates of delivery, but it is a paperwork notice that repeats this, not a new rule.
What do you keep instead of a certificate of delivery?
Business records that document the transfer, identify the goods and assign the drawback right, covering the data items listed in 19 CFR 190.10(b). The transferring party keeps them for three years after the claim liquidates (190.10(d)) and produces them when CBP asks; if they are missing, that part of the claim is denied (190.10(e)). Transfer records are not filed with the claim. A claimant who is not the exporter still needs the exporter's waiver and assignment of the right to claim (19 CFR 190.33 and 190.82).
Do older claims still use certificates of delivery?
Claims filed under the old law stay under 19 CFR Part 191 (191.0), which is where certificates of delivery still appear. Every new claim follows TFTEA and 19 CFR Part 190, so a source that describes Form 7552 as required for a current claim is out of date.
Where does Stable Software fit?
DrawbackAI by Stable Software keeps the documents behind each claim line, such as entries, commercial invoices and export bills, linked to the claim, so customs brokers can produce them when CBP asks and file for their importer clients under their own filer code and POA. Flat software license. No contingency, no percentage of the refund. See DrawbackAI.
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Frequently asked questions
What is a certificate of delivery in duty drawback, and when is it used?
It was CBP Form 7552, which documented a transfer of imported goods and assigned the right to claim drawback to the recipient. It is no longer used: since TFTEA, business records show transfers (19 CFR 190.10).
Do I still need certificates of delivery?
No. CBP does not request or accept Form 7552 on current claims. Keep business records of each transfer and produce them if CBP asks.
When were certificates of delivery eliminated?
For claims filed on or after February 24, 2018, under TFTEA, and for every claim after February 23, 2019, when filing under the old rules ended.
Do I file transfer records with my drawback claim?
No. Keep them for three years after the claim liquidates and produce them only when CBP asks (19 CFR 190.10).