Drawback Bond (Activity Code 1a): Accelerated Payment Rules

Under normal drawback procedure, CBP reviews and liquidates your claim before paying anything — by the time money moves, CBP has already confirmed you are entitled to it. Accelerated payment, authorized under 19 CFR 190.92, flips that order: CBP pays your estimated drawback amount up front, based on your own calculation, and liquidates the claim afterward. The regulation is explicit that accelerated payment is available only when CBP's review of your application "does not find omissions from, or inconsistencies with the requirements of the drawback law and part 190" — it is a privilege CBP grants, not an automatic right.

That reversal creates exposure CBP has to cover somehow, and the bond is the mechanism. 19 CFR 113.65 spells out exactly what you and your surety are on the hook for: if liquidation later shows CBP overpaid you, "the principal and surety, jointly and severally agree to refund on demand the full amount of any overpayment, as determined on liquidation of the drawback claim." A second condition covers claimants using the exporter's summary procedure — if CBP later determines the claim misdescribed the exported articles or misstated the facts of exportation, the same refund-on-demand obligation applies.

Practically, this means the bond never costs you anything if your claim was accurate. It exists purely to give CBP a guaranteed path to recover money it fronted you, in case your own estimate turns out to be wrong once the paperwork is fully reviewed.

Drawback refunds duties, taxes, and fees paid on imported merchandise that is later exported, used in exports, or rejected — so when the duty rate on your imported inputs goes up, the drawback available on the export side goes up with it, dollar for dollar. Since 2025, Section 301 China-origin tariffs and other tariff actions have stacked onto merchandise many manufacturers and exporters already claim drawback on (the IEEPA-based tariffs were struck down by the Supreme Court on February 20, 2026).

Here is the nuance almost nobody explains: not every tariff layer is drawback-eligible. CBP has stated that Section 301 duties are drawback-eligible — importers can recover up to 99% of Section 301 tariffs paid on qualifying exports. Meanwhile, antidumping and countervailing duties stay excluded under 19 CFR 190.3(b) because they function as remedial trade penalties, not ordinary duties.

Section 232 steel, aluminum, and copper duties, imposed under Section 232 presidential proclamations, have generally been excluded from drawback — but not anymore in every case. Under the April 2026 Section 232 proclamation, manufacturing drawback is available for certain products of a country with which the U.S. has an Agreement on Reciprocal Trade, when the metal was melted-and-poured (steel) or smelted-and-cast (aluminum/copper) in that country and the merchandise isn't subject to an AD/CVD order. Confirm current eligibility with CBP or your drawback broker. It is a narrow sourcing-specific carve-out, not a blanket reopening of Section 232 drawback.

For a claimant whose import mix carries Section 301-tariffed components, every dollar of that tariff flows into a larger accelerated payment request — and, under the 100%-of-AP formula, a larger required bond. AD/CVD exposure never moves the needle, because it is categorically non-refundable. Section 232 duties usually don't either — unless your metal inputs trace to a Trade Agreement Partner country and clear the AD/CVD-free test above, in which case they now count toward your accelerated payment amount too. Getting this distinction wrong in either direction either understates your bond need (risking a rejected AP request) or overstates it (paying premium on duty categories that were never going to be part of your claim).