CBP Blocks Drawback on Section 301 Brazil and Forced-Labor Duties

Key Points

• On August 12, 2026, CBP deployed ACE validation changes that disallow drawback for HTSUS classifications 9903.05.01 and 9903.05.20 through 9903.05.84.
• HTSUS 9903.05.01 covers Section 301 duties on certain products from Brazil; 9903.05.20 through 9903.05.84 cover Section 301 Forced Labor Import Duties.
• The block is enforced at the FD07 transaction level inside ACE, meaning claims that include these classifications will now fail validation rather than be accepted for review.
• The updated Drawback Error Dictionary, which lists all affected error codes, is available in the CATAIR Supporting Documents section on CBP's ABI page.

On this page

1. What changed in ACE drawback validations
2. Affected HTSUS classifications and tariff programs
3. How the FD07 validation block works in practice
4. Required actions for importers, brokers, and compliance teams
5. Key references

CBP updated its ACE drawback system on August 12, 2026, to reject FD07 drawback claims that include HTSUS 9903.05.01 (Section 301 duties on certain Brazilian products) or 9903.05.20 through 9903.05.84 (Section 301 Forced Labor Import Duties). Any pending or future drawback filing that covers duties paid under these chapter 99 provisions will now fail at the validation stage in ACE.

The links in this article go to the primary documents: the CBP CSMS notice and the official CATAIR guidance pages themselves. Read the source.

What changed in ACE drawback validations

CBP's CSMS #69535943, published August 14, 2026, announced that as of August 12, 2026, the FD07 drawback transaction in ACE was updated to disallow drawback claims tied to two specific groups of HTSUS chapter 99 classifications. The change is a hard validation block, not a soft warning, meaning ACE will reject the transaction outright rather than flag it for manual review.

Affected HTSUS classifications and tariff programs

Two distinct tariff programs are now off-limits for drawback:

• HTSUS 9903.05.01: Section 301 duties on certain products from Brazil.
• HTSUS 9903.05.20 through 9903.05.84: Section 301 Forced Labor Import Duties, a separate tranche of Section 301 actions targeting goods associated with forced labor.

Both classification groups sit in chapter 99 of the Harmonized Tariff Schedule of the United States, which is where temporary and special-program duty provisions are found. Duties assessed under these provisions were already non-refundable as a policy matter; this update encodes that policy directly into ACE validation logic.

How the FD07 validation block works in practice

FD07 is the ACE transaction type used to file accelerated-payment drawback and other drawback claim types. When a broker or filer submits an FD07 that references any of the newly blocked HTSUS classifications, ACE will return a validation error from the updated Drawback Error Dictionary. The claim will not advance. Filers who have already submitted claims containing these classifications and received acceptance should confirm their claim status directly with CBP, because the deployment date of August 12 may affect processing of claims in the pipeline.

Required actions for importers, brokers, and compliance teams

• Audit any open or planned drawback claims to identify whether duties paid under 9903.05.01 or 9903.05.20 through 9903.05.84 are included, and remove those line items before filing.
• Update internal drawback templates and classification checklists to flag chapter 99 classifications in the 9903.05 range as ineligible for drawback.
• Download the current Drawback Error Dictionary from the CATAIR Supporting Documents section on CBP's ABI page to see all active error codes and blocked classification ranges.
• Brief drawback software vendors or third-party filers on the August 12, 2026, effective date so system configurations are updated accordingly.

Key references

• CSMS #69535943 (Aug 14, 2026): CBP notice announcing the FD07 drawback validation update for HTSUS 9903.05.01 and 9903.05.20-9903.05.84.
• CBP CATAIR / ABI Supporting Documents: Contains the Drawback Error Dictionary with all current error codes and blocked classifications.
• Harmonized Tariff Schedule of the United States (USITC): Official HTS lookup for chapter 99 special-program classifications.