Self-file or managed program

How to file a duty drawback claim.

Filing a drawback claim is electronic, submitted to CBP through ACE by an ABI-certified filer. So the real question is not which form to complete, it is whether to self-file or run a managed program. Self-filing is possible, but it carries the software cost, the privilege timing, the recordkeeping, and the audit exposure. Answer four questions below to see which path fits, then walk the full process on both.

8 stepsFrom eligibility to audit defense
4 to 6 monthsTo approve CBP privileges, so start early
~30 daysTo get paid via ACH under accelerated payment
Interactive

Self-file or managed? Find your path.

Answer four quick questions. Your recommendation and a readiness meter update as you go.

1. Do you have CBP-certified drawback software, or the budget to license it?

2. Do you have in-house drawback expertise to pick the right provision and validate the calculations? Drawback is nuanced, and self-attested numbers are often wrong.

3. Can you prepare the ruling and privilege applications and manage the 4 to 6 month approval wait?

4. Do you have staff to maintain records for years and respond to CBP desk reviews?

Recommendation
Answer the four questions

As you choose Yes or No, we will point you to the path that fits, self-filing or a managed program.

Self-file readiness
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The path, step by step

Eight steps, on both paths.

The same sequence, seen from the self-filer's side and the managed side.

1

Confirm eligibility

Determine whether you have recoverable duty and which provision applies, unused merchandise, manufacturing, substitution, and so on. The provision drives everything downstream, including which privileges and rulings you need, so getting it right first is the most valuable step.

Self-fileYou interpret the statute and proclamations and choose the provision yourself. Drawback is nuanced enough that self-attested eligibility and calculations are frequently wrong.
With AllianceA licensed broker confirms the duty at stake and the optimal, compliant provision.
2

Secure privileges and, for manufacturing, a ruling, start now

Apply to CBP for the accelerated payment privilege and waiver of prior notice, including the one-time waiver for exports made before the privilege is granted. These are provision-specific and take roughly four to six months to approve, so you start them immediately and run steps 3 onward in parallel while the clock is running. Manufacturing drawback also requires a ruling, specific or general, before the manufacturing privilege application can be submitted.

Self-fileYou prepare and submit the ruling and privilege applications in the right order, then wait out the approval clock while building the rest.
With AllianceWe file the ruling and privileges first and in sequence, so the wait runs in the background while we build your program.
3

Gather and validate import and export data

Pull the import entry data and proof of export or destruction, with an 8-digit HTS on every line, then review and validate all of it. This is the evidence the claim stands on.

Self-fileYou gather and, critically, validate everything in-house.
With AllianceWe gather and validate the data. Many providers push this back on the client. We do not.
4

Match imports to exports

Pair imports to exports by direct identification or substitution. At any real volume this requires drawback software.

Self-fileYou license drawback software, which is costly, and run the matching yourself.
With AllianceEvery managed program should include the software, but most providers still use dated linear matching. We use global optimization to solve for the highest compliant recovery.
5

Post a bond and file the claim through ACE

Post a surety bond, single-transaction or continuous, which is required under the accelerated payment privilege and must be in place before submission, then file the drawback claim electronically through ACE by an ABI-certified filer.

Self-fileYou need ABI access and software to transmit the claim, plus the bond in place.
With AllianceWe arrange the bond and file the claim through ABI on your behalf.
6

Get paid

With the accelerated payment privilege secured in step 2, CBP issues the refund in approximately 30 days via ACH, rather than waiting for the entries to liquidate.

Self-fileSame fast payment, but only if you obtained accelerated payment early.
With AllianceThe privilege is already in place, so the refund lands on the fast timeline.
7

Maintain records

Keep the import and export documentation for three years from the date of liquidation of the claim. CBP can, and commonly does, extend liquidation, which lengthens how long you must hold the records.

Self-fileYou store and maintain all of it for the full retention period.
With AllianceWe gather and maintain the records. Many providers do not, or make the claimant do it.
8

Defend the claim

CBP can issue desk reviews of paid claims. Responding means producing the import and export documentation and the inventory records from your ERP to substantiate the transactions.

Self-fileThe review response is entirely on you.
With AllianceWe handle the desk review and substantiate the claim on your behalf.
Common questions

Filing duty drawback: FAQ.

Can I file duty drawback myself?

Yes, through ACE if you are an ABI-certified filer. But it requires drawback software, CBP privileges that take about four to six months to obtain, a bond, and staff to validate data, maintain records, and defend claims. Because drawback is nuanced and self-attested calculations are often wrong, most companies use a managed provider.

Do I need a ruling to file drawback?

Not for every provision. Manufacturing drawback requires a ruling, specific or general, before the manufacturing privilege application. Unused merchandise and other provisions do not. It depends on the provision you qualify under.

How long until I get paid?

With accelerated payment, about 30 days after filing, via ACH. That privilege takes four to six months to approve, so it is applied for as early as possible while the rest of the program is built in parallel.

How long do I keep records?

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

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Let a licensed broker run it.

Alliance owns the entire path, eligibility, privileges and rulings, validated data, optimized matching, filing, recordkeeping, and audit defense, so recovery happens without the burden landing on you.

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