Duty Drawback Recordkeeping: What to Keep and for How Long

Every duty drawback claim has to be backed by records that tie each export to an eligible import, and those records must be kept for three years after the claim liquidates. CBP can request them at any time during that window, and claims that cannot be supported get reduced or denied. Good recordkeeping is what makes a large claim safe.

The records CBP can ask for

• Import records: Entry summaries (CBP Form 7501) with entry numbers, line numbers, HTS numbers, quantities and duty paid.
• Export records: Commercial invoices, bills of lading or airway bills, the export filing, and carrier records for parcels.
• Inventory records: What links each export to the import it is designated against, such as SKU mappings and warehouse movements.
• Production records: For manufacturing drawback, bills of materials and production orders showing the imported or substituted material was used.
• Transfer records: When goods changed hands, the record under 19 CFR 190.10 showing each transfer. See our Form 7552 guide.

How long to keep them

Three years from the date the drawback claim liquidates, or longer where another law requires it. Because claims can reach back five years of imports and liquidation can take time, the oldest records behind a claim can end up being kept for close to a decade.

How to organize them

• One file per claim, with every claim line linked to its import entry, export record and the reason they were paired.
• Digital copies of every document, stored where they survive staff changes and system migrations.
• A clear owner for record requests, so a CBP request does not become a scramble.

Frequently asked questions

Who has to keep the records? The claimant, and in a supply chain, each party that transferred the goods keeps its own transfer records.

What happens if a record is missing? CBP denies the part of the claim that depends on it.

How Caspian keeps the file

Caspian builds the claim file as we match, with every line traceable to its source documents. See our export documentation guide or the full duty drawback guide.

Works Cited:

• 19 CFR Part 190, Modernized drawback
• 19 CFR 190.10, Transfer of merchandise