CBP Form 7552, the Delivery Certificate for Purposes of Drawback, is no longer requested or accepted by U.S. Customs and Border Protection. CBP retired the form in 2020 and now requires parties to document transfers of imported merchandise through their own business records instead.1Federal Register. Federal Register Vol. 85, No. 211, Friday, October 30, 2020, Notices If you’re looking at an old copy of this form or trying to figure out how to preserve drawback rights when merchandise changes hands, the work has shifted to private recordkeeping and electronic claim filing through the Automated Commercial Environment.
What the Form Used to Do
Form 7552 served as either a Certificate of Delivery or a Certificate of Manufacturing and Delivery, depending on whether the merchandise was transferred as-is or after being used to make a new product. When an importer paid duty on goods and later transferred them to another party, the form documented three things: that a transfer occurred, that the goods carried a potential drawback right, and that the right passed to the receiving party.2eCFR. 19 CFR 191.10 – Certificate of Delivery
Drawback is a refund of most of the duties paid on imported merchandise that is later exported, either as-is or after manufacture. If the goods change hands before export, there must be a documented chain linking the original duty-paid entry to the eventual export. Form 7552 was that link. Under the current rules in 19 CFR 190.10 and 190.24, the same link exists, but it lives in your commercial records rather than on a CBP form.3Federal Register. Federal Register Vol. 90, No. 113, Friday, June 13, 2025, Notices
What Your Business Records Need to Show
Because CBP no longer issues or accepts a specific certificate, the transferor and transferee simply keep their own records of each transfer. Those records need enough detail to identify the merchandise and tie it back to a duty-paid import. Capture the same core information the old form asked for:
- The names and addresses of the transferor and transferee.
- The import entry numbers being designated against the transfer.
- A merchandise description matching the import invoice.
- Quantity and unit of measure.
- The six-digit HTSUS classification from the original entry summary.
- The entered value per unit and duty paid, which drive the drawback calculation.
- For manufactured goods, the drawback ruling number (formatted NN-NNNNN-NNN) and the applicable type code: 41 for direct identification manufacturing, 44 for substitution manufacturing, or 46 for other.4Office of Information and Regulatory Affairs. Delivery Certificate for Purposes of Drawback CBP Form 7552
The records stay with the parties. CBP will ask for them if it audits or reviews a claim. If you can’t produce them, the portion of the drawback claim that depends on the missing records will be denied.2eCFR. 19 CFR 191.10 – Certificate of Delivery
How to File the Drawback Claim Itself
Every drawback claim must be transmitted electronically through the Automated Broker Interface. You cannot submit a claim through an ACE Portal account or hand it in at a CBP office. There are three ways to get a claim into ABI:5U.S. Customs and Border Protection. How Do I File a Drawback Claim?
- Self-file by purchasing ABI filing software and establishing a communications link with CBP.
- Hire a licensed customs broker to construct and transmit the claim on your behalf.
- Build the claim yourself and use a service provider to transmit it through their ABI connection.
The electronic filing requirement replaces most of the paper that once accompanied a drawback claim, including Form 7552.
How Long to Keep the Records
Drawback records must be kept until the third anniversary of the date the claim was paid.6eCFR. 19 CFR 163.4 – Record Retention Period That is a different clock than the five-year rule that covers most customs records, which runs from the date of entry. For drawback, the three years run from payment of the claim, so the retention window can stretch well past the underlying import date depending on when the claim is filed and liquidated.
Don’t Confuse It With In-Bond or Warehouse Delivery Forms
Form 7552 documented a commercial transfer for drawback purposes, which is not the same as moving merchandise under customs supervision. Physical movements between a pier and a bonded warehouse, or between bonded facilities, use CBP Form 6043 (Delivery Ticket), an annotated Form 7501 (Entry Summary serving as a permit), or Form 7512 (Transportation Entry and Manifest).7eCFR. 19 CFR 125.31 – Documents Used Under a Form 7552 transfer the goods might not move at all; ownership could change while the merchandise sat in the same warehouse. If your question is about physical custody rather than duty refund eligibility, the in-bond documentation is what you’re looking for, not Form 7552.