How to Capitalize on U.S. Duty Drawback

The White House recently announced new reciprocal tariffs under the International Emergency Economic Powers Act (IEEPA), but this time, there’s a key difference in the federal register—no duty drawback restrictions. Unlike previous tariffs in 2025, this round allows businesses to recover duties and taxes on qualifying goods. U.S. Customs and Border Protection (CBP) has issued guidance confirming that drawback is available under the executive order.

If you’re not taking advantage of duty drawback, you could be leaving money on the table. This often-overlooked CBP program lets companies reclaim duties paid on imported goods that are later exported or destroyed. If the term “duty drawback” is new to you, review our introductory article for a quick overview.

So how can you position your business to benefit from drawback under these new tariffs? Let’s walk through what you need to know—and what steps you can take now to prepare.

How can an importer and exporter prepare now to leverage drawback in the future?

You are always working “in the rear” with drawback, meaning, you can import and export products two years ago and claim drawback today, or up to five years from the import date into the future. This allows companies time to implement best practices today, so that you have a leg up to potentially claim drawback in the future.

Duty drawback is a process that requires evidence

While duty drawback is primarily about submitting data to CBP, those claiming drawback must be able to show CBP proof of what was imported and what was exported. This proof must exist in the form of documentation.

All import and export documents must be “linked” together via reference numbers. Below is just one example showing how documents can be linked together.

Additional tips and tricks for documentation and internal processes

Unique identifiers: Ensure that serialized products or those with unique lot numbers can be traced from import to export in your documentation.
HTS number support: Ensure you can substantiate the Harmonized Tariff Schedule (HTS) number under which your product is classified.
AES filing: Preferably, use the HTS number rather than the Schedule B when filing in the Automated Export System (AES).
SKU consistency: Maintain consistent SKU numbers on both import and export documentation. If this is not possible, a table will be required linking the SKUs.
Commercial invoice reflection: Ensure your documentation reflects your commercial invoices. For example, Entry Summary (7501) lines should match the lines and values on your import commercial invoice.

Proof of export documentation

The proof of export is the most scrutinized document by CBP. The export date listed on the bill of lading must match the date reflected in the actual drawback claim. Since this date is not always recorded for future reference, incorporating a method to consistently record this date will be highly valuable.

Routed versus standard exports

Routed exports, where the Foreign Principal Party in Interest (FPPI) manages the export, may create barriers to filing drawback claims. In contrast, standard exports, where the U.S. Principal Party in Interest (USPPI) arranges the transportation, provide the potential drawback claimant with more control over the data submitted and the documentation retained for drawback purposes. Conducting a cost analysis between routed shipments versus standard export shipments and examining your potential drawback refund can help determine which option makes more financial sense.

Streamlining drawback processes for better supply chain management

The drawback process can be labor-intensive and may not suit every company. However, integrating the practices mentioned above into your business processes can enhance your understanding of your overall supply chain, which is crucial in today's rapidly evolving trade environment.

C.H. Robinson's dedicated drawback team is ready to assess your eligibility, aiming to streamline the process, reduce risk, and maximize refunds.