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Guide

The records a drawback claim stands on.

Duty drawback is a documentation program. A claim is only as strong as the records behind it, and CBP can request them on a desk review years after the refund is paid. Three categories of records carry a claim: import records, export records, and inventory receipts and withdrawals. This guide explains each.

ImportProof the duty was paid
ExportProof the goods left the country
InventoryReceipts and withdrawals that link the two
Why it matters

Records are the claim.

A drawback refund is a legal assertion that specific duty-paid goods, or qualifying substitutes, were exported or destroyed. That assertion has to be backed by documents. Complete, organized, audit-ready records are what let a claim be filed with confidence and defended if CBP asks. Missing records are where recovery is lost.

1 · Import records

Proof the duty was paid.

Establishing the duty-paid import

Import records establish that duty was paid and how much. The core documents are the entry summary, CBP Form 7501, which shows the entered value, the HTS classification, and the duty, taxes, and fees, along with the commercial invoice and packing list that support it. These records fix the amount of duty available to recover on each import line.

They also anchor the classification. Because drawback and substitution turn on the 8-digit HTS, the import paperwork has to be accurate and consistent with what was filed in ACE.

2 · Export records

Proof the goods left the country.

Establishing the export

The export is the event that makes duty recoverable, so proof of export has to be clean. The supporting documents are the bill of lading or air waybill, the commercial invoice for the export sale, the Electronic Export Information filed in AES with its ITN, and the shipper's or freight forwarder's records. Where goods are destroyed rather than exported, the destruction is documented instead.

Export records also carry the part numbers, quantities, and dates that let each export be matched back to a duty-paid import, whether by direct identification or substitution.

3 · Inventory receipts and withdrawals

The link between import and export.

Tracing goods through inventory

Import and export records prove the two ends. Inventory records prove the middle. The receipt of duty-paid goods into inventory and their later withdrawal for export, sale, or production is what connects a specific import to a specific export. For direct identification and for manufacturing drawback, these movements are tracked by an accepted accounting method such as FIFO, LIFO, or low-to-high, and that accounting is what the claim relies on to show the goods it claims on are the goods that were exported.

Receipts show goods coming in and withdrawals show them going out, with dates, quantities, and part numbers that reconcile to both the import entries and the export records. Clean inventory records are often the difference between a claim that holds on audit and one that does not.

Retention

Keep everything, in order, for years.

Drawback records must be retained for three years from the date of liquidation of the claim. CBP can extend liquidation, which extends how long you must hold them, and the records have to be produced on demand during a desk review. That is why they are collected and organized as the claim is built, not scrambled for later.

We collect and hold the records

Many providers leave recordkeeping to the client. We gather the import, export, and inventory documentation, organize it against each claim line, and keep it audit-ready, so if CBP asks, the answer is already prepared.

Document management

And we defend the claim

If CBP issues a desk review, responding means producing exactly these records to substantiate the transactions. We handle the review and defend the claim on your behalf.

Claim advocacy
Common questions

Drawback documentation, answered.

What documents are required for duty drawback?

Three categories. Import records that prove the duty was paid, such as the entry summary and commercial invoice. Export records that prove the goods left the country, such as the bill of lading and the AES filing. And inventory records, the receipts and withdrawals that show the goods moving into and out of inventory. Together they substantiate every line of a claim.

How long do I have to keep drawback records?

Three years from the date of liquidation of the claim. CBP can, and commonly does, extend liquidation, which lengthens the retention period. Records must be produced on demand during a desk review.

Why does CBP want inventory receipts and withdrawals?

They connect a specific import to a specific export. For direct identification and manufacturing drawback, the receipt of duty-paid goods into inventory and their withdrawal for export or production, tracked by FIFO, LIFO, or low-to-high accounting, is how a claim proves the goods it claims on are the goods that were exported.

What counts as proof of export?

Documents showing the merchandise left the United States: the bill of lading or air waybill, the commercial invoice, the Electronic Export Information filing with its ITN, and the shipper's records. Proof of export is the event that makes duty recoverable, so it has to be clean.

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We will tell you what you have, what is missing, and how to close the gaps, as part of a free assessment. Then we keep the records audit-ready for you.

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