Preparation of Drawback Claims; Port of San Francisco by Karen Cheung

December 9th, 2010

July 2, 2010

TO: Drawback Brokers & Claimants

Subject: Preparation of Drawback Claims

In order to guide you in preparation of drawback claims San Francisco Drawback office has put together this informal list of tips and key points. This is not all inclusive, but does address some of the most frequent issues we have observed.


Where: Self filers and brokers with national permits can file drawback at any of the four locations:

Chicago Drawback Center
9915 Bryn Mawr
Rosemont, Illinois 60018

Houston Drawback Center
2350 North Sam Houston Parkway East – Suite 900
Houston, Texas 77032

New York/Newark Drawback Center
1100 Raymond Boulevard – Suite 310
Newark, New Jersey 07102

San Francisco Drawback Center
555 Battery Street
San Francisco, California 94111

A complete claim must have the following:

  • CBP form 7551 – Drawback Entry
  • CBP form 7553 – Notice of Intent or Waiver of Prior Notice, as appropriate
  • Coding sheets- for manual claims
  • Evidence of Exportation: Chronological Summary of Exports or export documents (may use section IV of CBP7551).
  • Consumption Entry Numbers (import schedules)
  • CBP form 7552 – Certificate of Manufacturing & Delivery (CM&D) when required
  • Entry Type 45 – except 1313(p) – a commercial interchangeability determination. We will accept claims without this, but will not accelerate or liquidate.
  • Entry Type 41 & 44 – ruling number in Block 8 of CBP7551, unless claimant is not a manufacturer and a CM&D designated. Claims lacking a ruling may be accepted but will not receive accelerated payment.

If any of the above is missing, claims will be rejected prior to input by CBP.

7553 – Notice of Intent to Export or Destroy: Should be filed at the port of export
For export: file with port of export at least 2 working days before export
For export 1313C: file with port of export at least 5 working days before export.
For destruction: file with port of destruction at least 7 working days before planned destruction

MPF and HMF: Claims requesting refund of MPF and HMF must include coding sheet and calculation worksheet in the drawback package.  Due to the de minimum of $25 and maximum of $485, when calculating MPF, refer to 19 CFR 191.51 (b) (2) to get the prorated MPF value per line item or unit of merchandise

Claim restructuring requirements: San Francisco requires claimants to restructure claims for administrative efficiency (19 CFR 191.53).  Failure to comply will result in rejection.

1. Claims should be submitted in straight cut, letter sized manila folders with the claim number clearly written on the right side of the tab and the claimant name on the left.  Do not staple or write anything on the outside of the folder.  Do not include carbon paper or extra copies of the claim.  If you require a dated stamped receipt, include a clearly labeled “broker copy” CBP 7551 and a self addressed, stamped envelope in the drawback package.

2. CBP form 7551, Section II & IV: Four summaries should be included with the claim:

  • Section II: import summaries sorted by entry number and part number, with subtotals and grand totals of quantity claimed and 99% duties,
  • Section IV: export summaries sorted by date and part number, with subtotals and grand totals of quantity claimed.
  • Blocks and headings on all summaries must be enumerated to agree with the CBP 7551.   Merchandise that can be broken down by color, style and size such as clothes, shoes or headphones must be broken down on the summaries.

3. Standard 12 font size, minimum 10 font size with 1.5 or double spacing on all summaries.

4. Summaries exceeding 30 pages should not be printed.  Instead, submit the first and last page of each report with the complete summaries on a CD.

5. Manual claims are limited to 24 import entry designations.  ABI claims are limited to 1000 import entry designations.

How to file claims: There are two options: ABI & Manual.

Filing ABI claims is the preferred method.  This can be done directly or by transmitting through a service bureau.  This will give you priority processing, fast accelerated payment, access to information on line and less documentation errors.  If you want a solid cash flow and stay completive in this economic environment, get ABI certified or use a service bureau.

Manual claims are at the bottom of our processing list.  The procedure is to do the initial review and ACS input no sooner than 89 day after filing.  We strongly encourage you to either use a service bureau to transmit these drawback claims or purchase drawback software and work with your ABI rep to become ABI certified for drawback.

*Diskette filing is no longer a mechanism for filing claims

Time Frames

Accelerated Payment:

ABI: If the claim is in proper form, it will be certified for payment by the third week from the date of submission.  The check should be issued 4-6 weeks after certification.

Manual claim: 3 months, if the claim was filed in perfect form.

Liquidation of drawback claims: Claims cannot be worked for final liquidation until the liquidation of the underlying consumption entries is final – 180 days after the date of liquidation.

Full Desk Review: There is no set time frame on when a full desk review must be completed.  The usual time frame for the specialists to complete a full desk review is between 3 months to 1 year.  The time frame depends on the specialist workload and on the complexity of the claim.  It is unreasonable to expect a specialist to have completed the review documents submitted for a full desk review within 30 days.

Telephone calls for status checks: Unless your claim is outside the standard time frames (if it was submitted without errors or deficiencies), do not contact the drawback office for a status report.

CBP 2010 Updates to the National Drawback Program by Maryanne Carney

December 9th, 2010

To enlarge, please click on image.