
*Revised April 13, 2026 to reflect recent CBP guidance on IEEPA tariff actions and the CAPE refund process.*

## What is Duty Drawback?

Duty drawback is a U.S. Customs program that functions like a tax refund for importers. If you import goods, pay duties on them, and later export or destroy those goods (or a substitute), you may be eligible to recover up to 99% of the duties paid.

However, not all 2025 tariffs are created equal. As trade policies have become more aggressive, the government has blocked refunds for certain "punitive" duties while allowing them for others.

## Which Duties Can You Claim Back? (The "Yes" List)

If you paid these duties, you can generally file a claim to get them back:

- **Standard Customs Duties (MFN):** The basic duties assigned to almost all products (Chapter 1–97) are fully refundable.
- **Section 301 Tariffs (China Trade War):** Despite being "punitive," these duties are eligible for drawback. This includes the massive levies on Chinese electronics, furniture, and machinery.
  - **Tip:** You can even claim these under "Substitution" rules, meaning you export similar goods rather than the exact same ones you imported.
- **Section 201 Tariffs (Safeguards):** Duties on specific industries like solar panels and large residential washers are eligible for refund.
- **General "Reciprocal" Tariffs:** The 10% tariffs recently applied to many global trading partners are typically eligible, treating them like standard duties.
- **Section 122 Duties (Temporary Surcharge):** The additional 10% *ad valorem* duties imposed pursuant to the February 20, 2026 Presidential Proclamation are available for drawback.

## Which Duties Are Lost Forever? (The "No" List)

The U.S. government strictly prohibits refunds on duties linked to national security or specific emergencies:

- **Section 232 Tariffs:** Duties on Steel and Aluminum (and their derivatives) cannot be drawn back. Once paid, this money is gone, even if you re-export the metal. (Note: Very specific, narrow exceptions exist under certain bilateral trade agreements, though the general rule for these national security duties remains ineligibility.)
- **Fentanyl & Opioid Sanction Tariffs:** Any duties imposed specifically under the emergency orders to combat fentanyl trafficking (often labeled IEEPA duties) are ineligible.
- **The "125% China" Reciprocal Tariff:** Unlike the general reciprocal tariffs, the specific, high-rate duties targeting China under recent emergency powers are generally ineligible for drawback.

## Status of IEEPA Tariffs and Refunds Going Forward

U.S. Customs and Border Protection (CBP) recently included updates regarding the **ending of certain tariff actions** under the International Emergency Economic Powers Act (IEEPA) in Harmonized System Update (HSU) 2605 on February 23, 2026.

**New IEEPA Duty Refund Process (CAPE):** For IEEPA duties where refunds *are* due (e.g., pursuant to court order), CBP is launching the Consolidated Administration and Processing of Entries (CAPE) tool in the ACE Portal on April 20, 2026. This new tool is designed to:

- Provide an electronic pathway to submit valid IEEPA duty refund claims.
- Consolidate refunds, including interest, rather than processing them entry-by-entry.
- Initially be limited to certain unliquidated entries and those within 80 days of liquidation.

## The "De Minimis" Shift

In the past, shipments under $800 (De Minimis) were duty-free, so there was nothing to claim back. With the 2025 suspension of De Minimis for Chinese goods, you now pay duties on these small packages.

- **The Result:** You technically can claim drawback on these now.

## Key Takeaway

If you are paying **Section 301**, **Section 122**, or **standard duties**, you are leaving money on the table if you export. If you are paying **Section 232** or **fentanyl duties**, factor that cost as a permanent expense—you won't see it again.

[Estimate your potential refund](/estimate) or [try Drawback Hub free](/subscribe) to start recovering eligible duties.


Not all 2025 tariffs are refundable. Learn which duties you can recover via drawback (Section 301, standard duties, Section 122) and which are lost forever (Section 232, fentanyl sanctions).

The Duty Layer Cake and Guide to What Can Be Drawn Back


Starting a duty drawback program is one of the most effective ways for businesses to recover costs and improve cash flow. Before you can claim your first refund, however, you need to navigate the U.S. Customs and Border Protection (CBP) enrollment process.

At Drawback Hub, we simplify this journey. [Our enrollment tools](https://app.drawbackhub.com/config/cbp_enrollment) collect your data once and help draft the complex documents required for each step below.

## Step 1: Set Up Your CBP Digital Foundation

Modern duty drawback is an electronic process. You cannot file paper claims, and CBP no longer issues paper refund checks.

- **ACE Secure Data Portal:** If you are the Importer of Record, establish an ACE Portal account to manage data and compliance.
- **Letter of Intent (LOI):** Submit a formal LOI on company letterhead to request participation in the Automated Broker Interface (ABI). CBP then assigns your unique 3-character filer ID code.
- **ACH Refund Enrollment (Mandatory):** Refunds are now electronic, so you must configure ACH details in your ACE Portal. Without ACH, approved refunds can remain in limbo until banking details are complete.

## Step 2: Apply for Drawback Privileges

Standard drawback is slow. To accelerate payments and unlock historical opportunities, new filers typically apply for combined privileges:

- **Accelerated Payment (AP):** Receive refunds in weeks instead of years.
  - **How to get it:** Furnish a Type 1A bond through the eBond system. This indemnity bond protects CBP if a claim is paid early and later adjusted.
- **Waiver of Prior Notice (WPN):** Export goods without providing CBP prior notice for physical inspection every time.
- **One-Time Waiver (Historical Claims):** Drawback claims can generally reach back 5 years from import date. If prior exports lacked CBP notice, this waiver is critical to preserve eligibility for those historical refunds.

## Step 3: Secure Rights for Complicated Relationships

The legal right to drawback usually defaults to the party that exported or destroyed the merchandise. In practice, the claimant is often a different entity.

- **Important for importers:** Even if you imported goods and paid duties, you may not automatically retain drawback rights after sale to another party for export.
- **Assignment of Drawback Rights:** If your company is the claimant but not the importer or exporter of record, secure a formal assignment document transferring rights to your entity.

## Step 4: Secure Manufacturing Rulings (If Needed)

If you do not plan to file manufacturing drawback claims, you can skip this step.

If you are a manufacturer, you need legal authorization to claim drawback on produced goods:

- **General Rulings (Pre-published):** CBP provides pre-approved ruling templates for common operations (for example, standard assembly and chemical reactions). You generally notify CBP of your intent to use one.
  - **How to choose:** [Review 19 CFR Part 190, Appendix A](https://www.ecfr.gov/current/title-19/chapter-I/part-190/appendix-Appendix%20A%20to%20Part%20190) to identify a matching ruling.
- **Specific Rulings:** If your process does not fit a general ruling, apply for a customized specific ruling with a detailed process description.

## Let Our Tools Do the Heavy Lifting

The enrollment process rewards precision. Drawback Hub guides you through each requirement, helps prepare the right documentation, and keeps your program moving without unnecessary delays.

[Estimate your potential refund](/estimate) or [try Drawback Hub free](/subscribe) to get started.


New to duty drawback? Learn the CBP enrollment steps, from ACE setup and ACH enrollment to privileges, assignments, and manufacturing rulings.

Navigating the CBP Enrollment Process: A Guide for New Duty Drawback Filers


Duty drawback is a U.S. and Canadian customs provision that allows importers to recover up to 99% of duties, taxes, and fees paid on imported merchandise when that merchandise is later exported, destroyed, or used in manufacturing.

## Why Duty Drawback Matters

If you import goods and then export them (or products made from them), you may be leaving money on the table. Duty drawback programs exist to encourage domestic manufacturing and export by refunding duties that would otherwise be a permanent cost.

## Who Can Benefit

- **Importers** who re-export goods
- **Manufacturers** who use imported materials in finished products that are exported
- **E-commerce and retail** businesses with international supply chains
- **Customs brokers and 3PLs** serving importer clients

## How Drawback Hub Helps

Drawback Hub provides software and services to **self-file** duty drawback claims with U.S. CBP and Canadian customs. Our platform streamlines data collection, claim building, and submission so you can recover refunds without the cost of traditional service bureaus.

[Estimate your potential refund](/estimate) or [try the platform free](/subscribe).


Duty drawback lets U.S. and Canadian importers recover duties paid on imported goods when those goods are later exported or used in manufacturing. Here's how it works.

Blog

The Duty Layer Cake and Guide to What Can Be Drawn Back

Navigating the CBP Enrollment Process: A Guide for New Duty Drawback Filers

What Is Duty Drawback? A Guide for Importers