Your First 90 Days of a Duty Drawback Program: A Success Checklist

A Step-by-Step Guide to Accurate Duty Drawback Filing for Trade Compliance Teams

If your organization is involved in importing or exporting, duty drawback can mean substantial savings. The process can be time-consuming, however, and even intimidating when you first get started. But with careful planning and a detailed timeline for the first 90 days, you’ll be set up for success. 

This how-to guide provides a detailed, actionable checklist to help you achieve quick wins and long-term compliance, so your duty drawback program delivers maximum value.

Why the First 90 Days Matter

Launching a duty drawback program is challenging, even for experienced compliance teams. But the rewards can result in refunds of up to 99% of customs duties, taxes, and fees paid on imported goods. 

The program is limited to specific types of goods, including imported merchandise and materials that are subsequently exported, destroyed, or used to manufacture exported items. Unused, defective, or non-compliant imported goods also qualify for duty drawbacks.

Precise documentation is critical to success and requires creating a strong system from the start. Common problem areas, such as missed deadlines and documentation gaps, can jeopardize eligibility and reduce duty recovery. 

The following 90-day checklist protects your organization and speeds up your ROI and confidence in compliance.

Weeks 1-2: Build the Foundation for Your Duty Drawback Program

Secure Executive Buy-In

• Develop a high-level business case for duty drawback. Be sure to include estimated potential recoveries and highlight the added benefits of strict compliance.
• Organize a kickoff meeting with everyone involved, including executives, finance managers, and trade compliance stakeholders.

Team Formation & Role Assignment

• Designate a project leader and a cross-functional team that includes operations, logistics, finance, and IT.
• Establish clear roles for each department involved in data collection, process mapping, reporting, and other responsibilities.
• Plan and develop communication channels for data sharing and information updates to avoid silos. 

Initial Education

• Organize a training session to outline the basics of drawbacks. Pay special attention to the most important deadlines and the cross-departmental responsibilities.
• Share summaries of regulatory requirements, including 19 CFR Part 191, U.S. Customs and Border Protection (CBP) guidance.

Weeks 3-4: Data Discovery & Process Mapping

Inventory Your Data

• Identify and organize all relevant import and export records. Examples include customs entries, bills of lading, manufacturing orders, and destruction certificates.
• Audit data systems for accessibility and completeness.

Conduct a Process Walkthrough

• Create flowcharts of your current import, export, and manufacturing processes with compliance checkpoints.
• Identify gaps or delays that could affect eligibility, such as record retention, exporter identification, or matching imports to exports.

Set Up Communications Channels

• Invite team members to your primary communication channels, such as a shared workspace or dashboard, to coordinate updates and document collection.

Weeks 5-8: Policy Development & System Integration

Draft Duty Drawback Policy

• Document internal rules for recordkeeping, data retention, and control points. Plan to retain all data for at least five years.
• Define escalation procedures for missed or late filings.

Standardize Documentation

• Create templates for key compliance documents, including import/export logs, certificates, and correspondence with brokers.

Integrate or Upgrade IT Systems

• Assess whether your current Enterprise Resource System (ERP), trade software, or manual records can provide the audit trail required by CBP.
• Start integrating drawback tracking into regular import/export processes and reporting tools.

Select Service Providers

• Develop a list of potential customs brokers or drawback specialists for program support or outsourcing.
• Schedule interviews.

Weeks 9-12: Pilot, Training & Pre-Filing Review

Test Pilot Claims

• Run sample drawback claims on a specific product or business unit to test your processes, documentation, and data accuracy.
• Identify and troubleshoot bottlenecks or compliance gaps before filing an actual claim.

Teamwide Training & Walkthroughs

• Conduct training refresher sessions with all involved personnel, using your trial run as a case study.
• Emphasize the consequences of errors, such as reduced refunds or increased audit risks.

Compliance Check

• Conduct an internal audit of your records and process documentation for CBP readiness.
• Perform a pre-filing review for missing information or inconsistencies.

Submit Your First Formal Claim

• When you’re confident with your rehearsal, file your first official drawback claim.
• Document lessons learned and areas for process refinement.

Maintaining Success Beyond the First 90 Days

Your first duty drawback claim is just the beginning. Schedule monthly check-ins with your team to update training, review process changes, and audit for compliance. Celebrate early wins and share metrics with leadership to maintain momentum.

Don’t leave duty drawback money on the table. Start with this 90-day success checklist, and your team will be primed for compliance, savings, and frictionless customs audits all year long.

Ready to unlock the full potential of duty drawback for your business?

Download our comprehensive guide, Duty Drawback 101, or schedule a free consultation with our trade compliance experts. Contact us today to keep your program running smoothly and profitably!