The Manufacturing Drawback Package — 19 U.S.C. 1313(a), Done Right.
For importers who bring in raw materials or components, manufacture or produce something in the US, and export the finished article. Every regulatory claim cited directly from 19 CFR Part 190.
Instant PDF · 30-day guarantee · Educational content, not legal advice
Importers who bring in raw materials or components, manufacture or produce something in the United States, and export the finished article. If that's not you, the Unused Merchandise Drawback Package or the broader Complete Duty Drawback & Tariff Refund Guide may fit better.
Five Sections. Every Claim Cited.
What Manufacturing Drawback Actually Is
Legal basis: 19 U.S.C. 1313(a) — drawback on articles manufactured or produced in the US with imported merchandise, later exported or destroyed under CBP supervision, not used in the US first.
Up to 99% of duties, taxes, and fees paid on the imported components is recoverable.
Real-world pattern: a company imports steel components, machines them into a finished part, exports the finished part. The imported-duty portion attributable to the exported article is drawback-eligible.
The Step Most Guides Skip — You Need a Ruling First
You cannot just file a manufacturing drawback claim. You must operate under either:
- General Manufacturing Drawback Ruling (§190.7) — a pre-approved description of a common manufacturing operation already published by CBP. Faster path if your operation matches one of the general rulings in Appendix A.
- Specific Manufacturing Drawback Ruling (§190.8) — required when your operation doesn't fit a general ruling. Application goes to CBP Headquarters, Entry Process and Duty Refunds Branch, Office of Trade.
The guide includes the official CBP sample application format language cited directly from 19 CFR Part 190, Appendix B.
Duration: an approved specific ruling remains in effect indefinitely unless no claim is filed for 5 years, or the company formally terminates it.
The Records That Actually Prove Your Claim
- Bill of Materials — identifies each component incorporated into the manufactured article.
- Formula — required where applicable; identifies the quantity of each element, material, chemical, or substance incorporated.
- Abstract or Schedule method — you must choose and state which method you use:
- Abstract — summary of total quantity used across all articles in a period (the default if unspecified).
- Schedule — quantity used per individual unit of product.
- Waste handling — how valuable waste recovered from manufacturing reduces the drawback calculation.
Worked Example
One complete example, end to end, using CBP's published sample formats — showing how the bill of materials, ruling application, and abstract records connect to an actual filed claim. Numbers, records, and workflow.
Common Rejection Reasons
- Ruling not obtained before filing.
- Bill of materials or formula inconsistent with actual production records.
- Wrong abstract/schedule method stated vs. the method actually used.
Educational guidance, not legal or customs-broker advice. All citations reflect 19 CFR Part 190 (Modernized Drawback under TFTEA); Part 191 is obsolete for new claims. CBP Form 7551 is no longer submitted. Confirm current requirements directly with CBP or a licensed customs broker before filing.