CBP Form 7552: The Drawback Delivery Certificate and What Replaced It

CBP Form 7552 was the Delivery Certificate for Purposes of Drawback. It traveled with imported goods as they moved between companies, so the party that finally exported or destroyed them could prove which import the duty came from. The form is gone. It was retired when drawback moved fully to the modernized rules and ACE filing on February 24, 2019, and a transfer record kept by the seller replaced it.

Why the form existed

Drawback belongs to whoever holds the right to it, and that is often a different company from the importer. A distributor buys imported goods and exports them. A manufacturer buys imported components and ships finished products abroad. For either one to claim, the drawback right has to follow the goods down the chain, with a record of each hand-off.

What replaced it

Under 19 CFR 190.10, the company that transfers the merchandise keeps a record of each transfer. Nothing is filed with CBP up front. The record has to show:

• Who received the goods, and the date of physical delivery
• The import entry number and entry line
• The quantity delivered
• The duties, taxes and fees paid on that quantity
• The import date and port of entry
• A description of the goods and the HTSUS number
• For substitution claims, the HTSUS number of the substituted goods

How long to keep it

The transferring company retains these records for 3 years from the date the related drawback claim liquidates, or longer when another law requires it.

What happens if the record is missing

CBP can ask the claimant for the transfer records at any point. If they can't be produced, CBP denies the part of the claim that depends on them.

Where this fits

Caspian maps each transfer in your supply chain, checks that the records carry every required element, and builds the duty drawback claim on top of them. For the notice CBP still requires before an export or destruction, see CBP Form 7553.

Works Cited:

• 19 CFR 190.10, Transfer of merchandise
• CustomsGenius: CBP Form 7552 Delivery Certificate Replaced by Transfer Records
• eCFR: 19 CFR Part 191, the pre-2019 drawback rules