The short answer
Compare what you imported with what you exported or destroyed over the last five years. Pull your duty-paid import lines from ACE (report ES-003 lists each entry line with its HTS number and duties), pull your export filings (AES reports in ACE), and match them by product, or by 8-digit HTS number when the goods are interchangeable. Matched lines can return up to 99% of the duties, taxes and fees you paid, as long as each claim is filed within five years of the import date.
Key takeaways
- Five years of history is in scope, because a claim can be filed up to five years after the import date.
- ACE Reports need an ACE Portal account. ES-003 gives the line-level tariff detail.
- Exporters can pull their AES filings from ACE. Keep commercial export records too, because AES data alone may not prove export.
- Reports ES-609 and ES-610 show import lines that someone else already used on a drawback claim.
Five steps to size your drawback opportunity
1.Pull five years of duty-paid imports
In the ACE Portal, run ES-003 (Entry Summary Line Tariff Details); ES-001 and ES-002 add header and line detail. You need an ACE Portal account, and new users wait 24 hours before running reports. Your customs broker can also export this from its entry records.
2.Pull five years of exports
Exporters can run AES reports in ACE, such as AES-201 (filer transactions), AES-202 (USPPI transactions) and AES-203 (agent-filed routed transactions). Census controls access to export data, so allow time for account setup. Keep invoices and bills of lading as well; CBP has said AES data alone does not necessarily prove exportation.
3.Find the overlap
- The same goods exported unused: unused merchandise drawback.
- Interchangeable goods under the same 8-digit HTS subheading: substitution drawback.
- Imported components in products you export: manufacturing drawback, which needs a ruling.
- Goods destroyed under CBP supervision, and defective goods returned to the supplier.
4.Remove what you can't claim
- Import lines already used on someone else's claim (reports ES-609 and ES-610).
- Duties that are not drawback eligible, such as many Section 232 duties. See Section 301 drawback.
- IEEPA duties, which are refunded through CBP's separate CAPE process. CBP encourages putting drawback-eligible entries on a CAPE declaration before filing a drawback claim on them.
5.Estimate the refund
Take up to 99% of the eligible duties, taxes and fees on the matched lines. Substitution claims are capped by the lesser-of rule, and the matching method changes the total; see drawback matching. A customs broker or drawback provider can run this match on your data before you commit to a program.
Who qualifies for duty drawback?
You may qualify if you paid duties, taxes or fees on imports and those goods, interchangeable goods, or products made from them were exported or destroyed under CBP supervision within the claim windows. The exporter or destroyer usually claims, and the right can be transferred between companies with business records. See duty drawback.
What data do you need from your ERP and your customs broker?
- From your customs broker or ACE: entry numbers, line numbers, 10-digit HTS numbers, duties paid, entered values and quantities.
- From your ERP: export shipments with dates, quantities and product identifiers; for manufacturing, bills of materials and production records.
- A product master that maps your SKUs to HTS numbers, so imports and exports can be matched.
- Export evidence: EEI filings plus invoices and bills of lading.
Where does Stable Software fit?
DrawbackAI by Stable Software runs this matching for customs brokers and their importer clients, and the broker files the claims under its own filer code. If your broker doesn't offer drawback yet, point them to Stable Software for brokers. Flat software license. No contingency, no percentage of the refund.
Sources
Related
Frequently asked questions
We're a US importer and we also export some of the same products. How do we find out if we're leaving duty drawback money on the table?
Pull five years of duty-paid import lines from ACE (report ES-003) and five years of exports (AES reports), match them by product or by 8-digit HTS number, remove lines that can't be claimed, and estimate up to 99% of the duties on the matches. A customs broker or drawback provider can run the match for you.
How do I know if my company qualifies for duty drawback?
If you paid duties on imports and those goods, interchangeable goods or products made from them were exported or destroyed within five years of import, you likely have a claim. The exporter or destroyer usually holds the right to claim, and it can be transferred.
What data do I need from our ERP and our customs broker to start a duty drawback program?
Import entry lines with HTS numbers and duties paid, export shipments with quantities and product identifiers, a SKU-to-HTS mapping, export evidence, and for manufacturing, bills of materials and production records.
How do I calculate how much duty drawback I can recover?
Up to 99% of the eligible duties, taxes and fees on the import lines you match to exports or destructions. Substitution claims are capped by the lesser-of rule, and duties that are not drawback eligible are excluded.