On Aug 12, 2026, CBP deployed ACE updates to its FD07 drawback validations that quietly disallowed drawback claims for the newest Section 301 classifications — including the 25% Brazil action (HTSUS 9903.05.01) and the forced-labor duties covering ~60 economies (9903.05.20–84). Six days later, on Aug 18, CBP confirmed the error and put the correct validation back.

The bottom line: Section 301 duties remain drawback-eligible. The trap is in the gap. If your broker or drawback filer assumed “ACE rejected it, so it’s not eligible,” they may have skipped claims that should have been filed.

For brands processing in China and re-exporting to the US, this is the recovery channel most often left on the table. We see three common misses: (1) the new Section 301 layers filed after July 24, 2026 never reviewed for drawback, (2) the 25% Brazil action on entries after July 22 treated as unrecoverable, (3) IEEPA refund filings from Phases 1–2 not cross-checked against Section 301 exposure.

CBP’s own position is clear: drawback applies where duties were legally paid and the merchandise is subsequently exported or destroyed under 19 USC 1313. Section 301 duties are not exempt.

Contact: yuanbo@thecustoms.com.cn

Comment ‘guide’ and we’ll send you a cross-border drawback eligibility checklist covering Section 301, Section 232, and the new forced-labor layers.

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