The Three Core Duty Drawback Programs
Sasha Bozic
4 mins
Nov 18, 2025
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To transform customs duties from a sunk cost into a financial recovery, you must first understand the three principal types of U.S. duty drawback: Manufacturing, Unused Merchandise, and Rejected Merchandise. Each program is tailored to a specific business model. Selecting the right one is a strategic decision that dictates the documentation, regulatory standards, and operational processes required to maximize your refund.
Manufacturing Drawback
This program is designed for companies that import materials, use them to produce a new article in the U.S., and then export the finished product. It is governed by 19 CFR Part 190, Subpart B.
Best For: Vertically integrated manufacturers and any business that adds value to imported components before exporting.
Key Methods: Claimants can use Direct Identification to trace specific imported materials through production or Substitution, which allows for the use of domestic or other duty-paid materials classifiable under the same 8-digit HTS code.
Timeframe: The export must occur within 5 years of the import date of the designated materials. A successful manufacturing drawback program requires robust data management to prove the link between the imported components and the exported goods.
Unused Merchandise Drawback
This program is ideal for distributors, wholesalers, or any business that imports goods and later exports them in the same condition. It is governed by 19 CFR Part 190, Subpart C.
Best For: Distributors, wholesalers, and companies with high inventory turnover of finished goods.
Key Definition: "Unused" allows for incidental operations like testing, cleaning, or repackaging that do not amount to manufacturing.
Substitution Standard: Exported goods must be "commercially interchangeable" with the imported goods designated for the claim.
Timeframe: The export or destruction must occur within 5 years of the import date.
Rejected Merchandise Drawback
This program allows for the recovery of duties on imported goods that are returned to the supplier or destroyed because they are defective or do not conform to specifications. It is governed by 19 CFR Part 190, Subpart D.
Best For: Any company that needs to return non-conforming goods to foreign suppliers, recovering duties paid on unusable inventory.
Documentation: Substantiating a claim requires clear proof, such as correspondence with the supplier or internal quality control reports.
Timeframe: The merchandise must be exported or destroyed within 5 years of the import date. This program is a key tool for quality control, helping businesses mitigate financial losses from substandard imports.
Strategic Program Comparison
Feature | Manufacturing Drawback | Unused Merchandise Drawback | Rejected Merchandise Drawback |
Core Purpose | For imported materials used to produce an exported article. | For imported goods exported in the same condition, unused. | For imported goods returned or destroyed because they are defective or non-conforming. |
Key Timeframe | Export within 5 years of import. | Export/destroy within 5 years of import. | Export/destroy within 5 years of import. |
Substitution Standard | Same 8-digit HTS number. | "Commercially interchangeable." | Generally not applicable. |
"Caspian Touch" Insight | Ideal for value-added exporters. | Ideal for distributors and wholesalers. | A key tool for quality control. |
How Caspian Can Help
Navigating drawback regulations is complex. Caspian simplifies the process with technology and deep customs expertise, helping you identify the right programs and maximize your recovery. Our solutions include automated transaction tracking, compliance monitoring, and claim preparation. With Caspian, you can focus on your business while we handle the complexities of duty drawback. Ready to discover your potential savings? Contact our specialists for a free consultation.
Works Cited:
19 CFR Part 190 -- Modernized Drawback - eCFR, accessed October 24, 2025, https://www.ecfr.gov/current/title-19/chapter-I/part-190
