Duty Drawback Refund Estimator

US duty drawback law (19 U.S.C. §1313) lets importers recover up to 99% of duties paid on goods that are re-exported, used in manufacturing exports, or destroyed as non-conforming. The remaining 1% is retained by CBP. Section 301 (China) duties are drawback-eligible; Section 232 (steel/aluminum/copper) duties are generally not. This estimator applies the statutory 99% rate to your eligible duties to show a potential gross recovery and a net figure after a typical broker contingency fee (10–25%). Five-year statute of limitations applies from each import date.

Primary sources: 19 U.S.C. §1313 (Cornell LII); 19 CFR Part 190 (eCFR); CSMS #18-000419 (CBP, Jul 3 2018) confirming Section 301 drawback eligibility.

Step 1 — Choose your drawback type

Pick the category your goods fall under. It determines which Section 232 exception (if any) can apply.

Before you rely on this number

  • This is a mathematical estimate of the MAXIMUM potential recovery, not a guarantee. CBP must approve each drawback claim; they verify documentation independently.
  • Section 232 duties (steel, aluminum, copper, autos) are generally not recoverable via drawback. A narrow manufacturing drawback exception opened April 6, 2026 for specific clause-13 conditions.
  • DO NOT file drawback for IEEPA duties — those are refunded via CBP's CAPE portal (for entries liquidated ≤80 days ago) or via protest (81–180 days post-liquidation). Use the IEEPA Refund Estimator.
  • Drawback requires original import documentation (CBP Form 7501 / entry summary), export proof, and for manufacturing drawback, production records. Without documentation, a claim cannot be filed regardless of the estimated amount.

Duty drawback FAQs

What is duty drawback?

Duty drawback is a U.S. Customs program (19 U.S.C. §1313) that refunds up to 99% of the duties, taxes, and fees you paid on imported goods that later leave U.S. commerce. There are three main types. Manufacturing drawback (19 U.S.C. §1313(a) direct, §1313(b) substitution) applies when you import components, use them to make an article, and export the finished article. Unused merchandise drawback (19 U.S.C. §1313(j)(1) direct, §1313(j)(2) substitution) applies when you import goods and export them as-is without using them in the U.S. Rejected merchandise drawback (19 U.S.C. §1313(c)) applies when goods are non-conforming, defective, or shipped without consent and you return or destroy them. All three cap the refund at 99% of eligible duties; CBP keeps the remaining 1% under 19 U.S.C. §1313(l)(2)(B).

Which of my duties are eligible for drawback?

Ordinary ad valorem duties, the merchandise processing fee (MPF), and the harbor maintenance tax (HMT) are eligible under 19 CFR §190.3. Among trade remedies, Section 301 (China Lists 1–4A) duties ARE eligible — CBP confirmed this in CSMS #18-000419 (Jul 3, 2018). The Section 122 balance-of-payments surcharge is also eligible (CSMS #67844987, Feb 23, 2026). Section 232 duties on steel, aluminum, copper, and autos are generally NOT eligible: the steel/aluminum proclamations and the auto proclamation expressly bar drawback. One narrow exception opened April 6, 2026 (Proclamation 11021 / CSMS #68253075) for manufacturing drawback on Section 232 articles meeting the proclamation's clause-13 conditions — but unused and substitution drawback under §1313(j) stay barred for 232 goods. Keep IEEPA duties out of your drawback total entirely; they are recovered a different way.

How much can I realistically recover after fees?

Start with your eligible duty base — total recoverable duties over the last five years, minus any Section 232. The statutory gross recovery is 99% of that base. Most importers engage a drawback broker or attorney on a contingency basis, typically 10–25% of the recovery, with the mid-market around 17.5%. After a 10–25% fee, your net take-home lands roughly between 74% and 89% of your eligible duty base. Example: on $1,000,000 of eligible duties, gross recovery is $990,000; at a 17.5% fee you net about $816,750. This estimator shows both the gross and net figures so a compliance manager or CFO can size the opportunity before committing to a filing engagement.

What is the time limit for filing drawback?

You have five years from each import date to file a drawback claim, under 19 U.S.C. §1313(r)(1) — the claim must be filed "not later than 5 years after the date on which merchandise on which drawback is claimed was imported." The clock runs per entry, not per claim, so older entries fall out of eligibility on a rolling basis. Any entry imported more than five years before today is time-barred, and no amount of documentation revives it. If you have a backlog of eligible exports, the entries nearest the five-year mark are the ones to prioritize before they expire.

Does GingerControl file drawback claims?

No. GingerControl is an AI trade-compliance platform, not a licensed drawback broker, and we do not file drawback claims. What we do is quantify your recoverable amount, identify which duties are eligible (correctly excluding Section 232 and IEEPA), and scope the claim so you walk into a filing engagement knowing the size of the prize. Execution — the actual claim, the CBP ruling, and the documentation package — is handled by a licensed drawback attorney or customs broker partner. This keeps the estimate independent and the filing in the hands of a licensed specialist.

How is drawback different from IEEPA refunds?

They are two separate recovery channels and should never be mixed. Drawback is the statutory §1313 program: it refunds duties on goods you re-export, use to manufacture exports, or destroy — a forward-looking program tied to the movement of goods. IEEPA refunds are different: they return duties paid under IEEPA tariffs that the Supreme Court struck down in February 2026, and they run through CBP's CAPE process (for recently liquidated entries) or a protest under 19 U.S.C. §1514 (81–180 days post-liquidation) — not through drawback. Drawback for the IEEPA fentanyl track was expressly barred by EO 14195. Put IEEPA duties in the IEEPA Refund Estimator, and keep only genuinely drawback-eligible duties in this tool.

More free customs tools

Working a refund or deadline? Try the Protest Deadline Calculator, the FTZ Savings Estimator, or browse all customs tools.

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