What Are Your 2021–2026 Entries Worth?
99% of duties back, 5 years retroactive. 60-second estimate.
How much do you import per year?
Total declared value across all entries. A rough range is fine.
The Drawback Library
Most recovery programs look forward. Duty drawback looks backward — five full years backward, from each individual import entry. Standing in mid-2026, that window reaches to mid-2021: before IEEPA, before Section 122, spanning the priciest stretch of Section 301 and Section 232 duty collection in modern American trade history. If your company imported and re-exported at any point in that window, you are holding an unclaimed, expiring asset. This guide walks through exactly how the 5-year window works, what sits inside yours, why the first claim is the largest you will ever file, and what it takes to execute a lookback claim before the oldest entries expire. For the full program overview, start with our pillar guide at /duty-drawback.
How the 5-Year Window Actually Works
The rule comes straight from 19 U.S.C. § 1313, as modernized by TFTEA in 2018: a drawback claim must be filed within 5 years of the date of import entry. Three details matter more than importers expect:
- The clock runs from the import date, not the export date. A container entered in August 2021 and re-exported in 2024 is claimable until August 2026 — the export timing is irrelevant to the deadline, as long as it happened within the window.
- The window is per-entry, not per-company. You don't have one deadline; you have hundreds or thousands of them, one per entry, expiring continuously in the order you imported.
- There is no extension mechanism. An expired entry is gone. CBP has no discretion to accept a claim on a 2020 entry in 2026, no matter how clean the documentation.
The practical translation: every month you wait, the oldest month of your import history falls off the back of the window — permanently. In June 2026, your June 2021 entries are dying. In July, the July 2021 entries follow.
What's Inside Your 2021–2026 Window
The five years currently claimable are not ordinary years. They span the most expensive duty environment American importers have ever operated in:
- Section 301 on Chinese goods: 7.5% to 100% across Lists 1–4B, the entire window. If you imported from China in 2021-2022 — before the great sourcing diversification — those entries carry your highest duty loads.
- Section 232 steel and aluminum: 25%, doubled to 50% in June 2025. Importers of metal goods paid structurally elevated duties through the entire window.
- MFN base rates on everything else: apparel at 10-32%, footwear up to 37.5%, food products, machinery — the ordinary tariff schedule kept running underneath everything.
A worked example. A consumer-products importer brought in $4M per year from China across 2021-2025 at a blended 15% duty (MFN + Section 301), and re-exported 25% of it to Canadian and Latin American distributors. The drawback math per year: $4,000,000 × 15% × 25% × 99% = $148,500. Across the five-year lookback: roughly $742,500 — claimable today, in a single filing.
The Expiring-Asset Math: What Waiting Costs
Treat the lookback like what it is: an asset with a burn rate.
Using the example above — $148,500 per claim-year — each month of delay expires one-twelfth of the oldest year, about $12,375. Wait six months and roughly $74,000 of recoverable duty is gone. Not reduced, not delayed: extinguished, with no appeal.
The burn rate is steepest for exactly the importers with the most at stake. If you were importing heavily from China in 2021-2022 and have since diversified to Vietnam or Mexico, your highest-duty entries are your oldest — the ones expiring first. The sourcing decisions that reduced your go-forward duty bill also mean your recoverable history is front-loaded into the years currently falling off the window.
The first drawback claim of your company's life is the largest one you will ever file. Every month of delay makes that permanently less true.
Your Oldest Entries Expire First — Run the Number
Imports × duty rate × export share × 99% × 5 years.
How much do you import per year?
Total declared value across all entries. A rough range is fine.
The Records You Need Still Exist
The reflexive objection to a 5-year lookback claim is documentary: "we don't have records from 2021." You almost certainly do — in systems that were keeping them for you:
- Import side: ACE. Every entry your broker filed — entry number, HTS codes, declared values, duties paid — lives in CBP's own ACE system, retrievable through an ACE portal account or from your broker's archives. This is the same Form 7501 data importers pulled for CAPE filings.
- Export side: AES filings and carrier records. Export shipments above $2,500 generated Electronic Export Information filings in the Automated Export System. Freight forwarders and carriers retain bills of lading and air waybills for years.
- TFTEA substitution closes the gaps. Under the post-2018 rules, you match imports to exports at the 8-digit HTS level, not unit-by-unit. You don't need to prove the specific widget exported in 2023 came from the specific container entered in 2021 — only that both carried the same 8-digit classification and fall inside the window.
Reconstructing five years of drawback support is a data-pull project measured in weeks, not a forensic excavation measured in years.
How a Lookback Claim Gets Executed
The sequence for a retroactive claim mirrors a standard drawback filing, scaled up:
- Pull the full 5-year import file from ACE — every entry, every HTS line, every dollar of duty, 2021 forward.
- Assemble the export/destruction file — AES records, bills of lading, destruction certificates — for the same period.
- Run the substitution match at the 8-digit HTS level: which exported goods pair with which imported duty payments.
- Prioritize by expiration. Claims are built oldest-entries-first, so the 2021 and 2022 duty — the money closest to extinction — gets filed ahead of everything else.
- File CBP Form 7551 through the ACE Drawback module, with accelerated payment privilege requested so payment arrives in weeks rather than the 6-12 months of standard liquidation.
A competent filer runs steps 1-3 as a screening exercise before you commit to anything — which means you can know what the five years are worth before spending a dollar. Contingency engagements, like the ones our partner network offers through the /lp/drawback-estimate funnel, only charge against recovered duty.
Who Should Move First
The lookback is most urgent for three profiles:
- Former China-heavy importers. Highest 2021-2022 duty loads, oldest entries, fastest-expiring recovery. Every month matters.
- CAPE filers. If you filed an IEEPA refund claim, your entry data is already reconciled — the marginal effort of a drawback screen is small, and the same entries may carry a second refund. See our companion guide on stacking drawback with IEEPA refunds.
- Manufacturers and distributors with steady export percentages. A stable 20-40% export share across five years compounds into a six-figure first claim at surprisingly modest import volumes.
If any of those describe your operation, the screening question — what would the five years be worth? — costs 60 seconds to ask.
Key Takeaway
The 5-year lookback is the single most valuable and least understood feature of duty drawback. It converts the program from a go-forward optimization into a retroactive recovery event: up to five years of accumulated duty — paid through the most expensive tariff era in US history — claimable in one filing, at 99 cents on the dollar. But it's a wasting asset. Every month, the oldest entries expire permanently, and for most importers the oldest entries are the most valuable ones. Run the estimate, screen the five years, and file oldest-first. The full program mechanics are covered in our pillar guide at /duty-drawback.
Calculate Your Import Duty
Get an instant estimate for your specific product, country, and shipment value.
Open Tariff Calculator