CBP will no longer allow drawback claims for Section 301 duties under HTSUS 9903.05.01 and 9903.05.20–9903.05.84 effective August 12, 2026.

CBP has implemented a substantive change to drawback eligibility for certain Section 301 duties. Effective August 12, 2026, FD07 validations in ACE have been updated so that drawback is disallowed for HTSUS 9903.05.01, which covers Section 301 duties on certain products from Brazil, and for HTSUS 9903.05.20 through 9903.05.84, which cover Section 301 forced labor import duties.

This change does not alter the underlying Section 301 duty rates or the requirement to pay those duties at import. Instead, it removes the ability to recover those specific Section 301 assessments through drawback. As a result, total net duty cost for exports or destroyed merchandise that previously might have been eligible for drawback will increase where these Chapter 99 provisions apply.

For customs brokers and trade compliance teams, immediate system and process updates are required. Drawback filing logic (both internal and in any third-party software) must be updated to prevent inclusion of duties paid under HTSUS 9903.05.01 and 9903.05.20–9903.05.84 in drawback claims. ACE will now reject such claims via FD07 validations, so pre-filing checks should be implemented to avoid repeated errors.

Review all pending, in-preparation, or planned drawback claims to identify any that rely on Section 301 duties under these Chapter 99 numbers. Those claims will no longer be allowable and should be revised to exclude these duties. Communicate this change to affected importers/exporters so they can adjust financial forecasts, pricing, and sourcing decisions, particularly where Section 301 forced labor-related duties are significant.

Compliance teams should consult the updated Drawback Error Dictionary in the CATAIR Supporting Documents for specific error codes and messaging associated with FD07 rejections. Coordination with IT and ABI service providers is recommended to ensure that the new validations are fully integrated and that users understand the new non-drawbackable status of these Section 301 duty lines.