Section 232, Section 301, and Section 122 duties are all eligible for drawback under standard rules. Drawback recovers up to 99% of these duties (along with base MFN). MPF and HMF are NOT eligible for drawback. For SMB exporters paying high effective tariff stacks, drawback can recover meaningful percentages of total duty.
This guide covers Drawback for Section 232, 301, and 122 Duties. Duty drawback recovers up to 99% of duty on imported goods that are subsequently exported, destroyed, or used to manufacture exported goods.
For SMB importers, the practical implementation depends on volume, sector, and specific operational structure.
Section 232 drawback eligibility
Section 232 steel, aluminum, copper, pharma duties are recoverable through drawback. Calculate at the per-line-item level.
Section 301 drawback eligibility
Section 301 China duties recoverable. List 1, 2, 3, 4A all eligible.
Section 122 drawback eligibility
Section 122 surcharge duties recoverable. Specifically eligible despite the Section 122 surcharge being temporary.
Calculation example
Imported component duty: base 5% + Section 232 25% + Section 122 (NOT applied, S232 in lieu) = 30% effective. Drawback recovers up to 99% of all 30%.
Frequently asked questions
When is this most relevant?
For SMB importers with active duty exposure or those evaluating duty mitigation options.
What documentation is required?
Varies by topic. Core: CBP Form 7501, supplier certificates, BOM analysis, manufacturing process documentation.
How long does this take to implement?
Simple cases 2-4 weeks; complex setups 8-16 weeks. Some moves require binding rulings adding 30-90 days.
What does this cost?
Project scope: $5,000-$25,000 for most engagements. Ongoing retainer for active operations.
How do I begin?
Book a 15-minute scoping call. We confirm fit and scope before any engagement.
Get started
Run a drawback opportunity audit on your import-export profile. Fixed-fee or contingency.