Drawback is generous on the amount and strict on the timing. The refund is 99 percent of the duties, taxes, and fees paid, but the right to claim it expires, and it expires on a schedule that is easy to misread.
The first clock is the export clock. The goods, or the substitute goods for a substitution claim, must be exported or destroyed within five years of the date of importation. The clock starts on the import date, not on the date the entry liquidates, and not on the date the goods arrive in the warehouse. For unused merchandise drawback, the five-year rule is the whole game: the exported goods must leave within five years of the import date of the merchandise the claim draws on.
The second clock is the filing clock. The claim must be filed within five years of the original import date, and for most claim types within one year of the export. The two limits run together, so a claim filed five years after import but two years after export is late on the second limit even though it meets the first. The third clock is the record clock. Records must be retained for three years after the drawback claim is paid, and CBP can ask for them in that window. A claim paid and a file shredded is a refund CBP can take back.
The miss is almost never the filing. It is the export. Goods sit in a warehouse, the export gets delayed, the five years pass, and the drawback on that inventory quietly dies. The inventory record is what saves it: tracking from import to export showing the quantity and HTS line moved through inventory, so the export can be matched to the import entry line it draws on. Without that tracking, the claim cannot connect the export to the import, and the connection is the claim.
Substitution makes the tracking harder and the deadline easier to miss. A substitution claim exports commercially interchangeable goods, not the exact goods imported, and the match is by 8-digit subheading rather than by lot or serial number. That flexibility helps with the inventory, and it hurts with the clock, because the export that qualifies might be a routine shipment nobody flagged as a drawback export. Substitution drawback is where most of the missed deadlines live, because the goods that qualify are the ones that look ordinary.
Put the dates in a system, not in someone's head. Every import entry with drawback potential gets an expiry date five years out, and every export gets matched to an import line within a week, not at year end. The claim itself is filed electronically in CBP's ACE system, and accelerated payment is available against a bond, which lets CBP pay the claim before liquidation. CBP pays within 90 days after liquidation, and refunds have issued electronically since February 6, 2026.
The records are the cheapest insurance in the process. Keep the import entries, the export documentation, the inventory records, and the claim form together, and keep them for three years after payment, not three years after filing. Drawback claims on re-exports show the same pattern: the claims that pay are the ones with a complete file, and the claims that fail are the ones where the file was assembled after the deadline passed. The five-year clock does not send a reminder. Set your own.
The goods must be exported or destroyed within five years of the date of importation. The clock starts on the import date, not on liquidation or arrival in the warehouse.
The claim must be filed within five years of the original import date, and for most claim types within one year of the export. Both limits apply, so the earlier one controls.
Records must be retained for three years after the drawback claim is paid. CBP can ask for them in that window, and a claim paid with a shredded file is a refund CBP can take back.
Substitution drawback lets you export commercially interchangeable goods instead of the exact goods imported, matched by 8-digit subheading. It helps with inventory, but the qualifying export can be a routine shipment nobody flagged.