CBP Form 7552: Delivery Certificate Replaced by Transfer Records

Key Points

• CBP Form 7552, Delivery Certificate for Purposes of Drawback, was abolished as of February 24, 2019, when drawback moved to TFTEA rules and ACE-only filing.
• The certificate was replaced by the transfer record described in 19 CFR 190.10, which the transferor must maintain rather than file with CBP.
• A compliant transfer record must carry eleven data elements, including the recipient, delivery date, import entry and line, quantity, duties, taxes and fees, import date, port, source party, description, the 10-digit HTSUS number, and the substituted HTSUS number.
• Transfer records must be retained 3 years from liquidation of the related drawback claim, and the trade still colloquially calls them "the 7552."
• As of September 2026 CBP Form 7552 remains abolished and the 19 CFR 190.10 records rule applies; confirm the current status before relying on either.

On this page

1. What CBP Form 7552 was and what replaced it
2. At a glance
3. Why CBP Form 7552 was abolished
4. What the 19 CFR 190.10 transfer record must contain
5. Who is responsible for the transfer record and when
6. Common CBP Form 7552 and transfer record failures
7. How CBP Form 7552 relates to other drawback and customs forms
8. Frequently asked questions
9. What importers and brokers should do
10. Key references

The links in this article go to the primary documents: the regulations, official CBP form pages, and the tariff schedule itself. Read the source.

CBP Form 7552, Delivery Certificate for Purposes of Drawback, was the paper certificate a transferor gave a drawback claimant to prove the chain of custody of merchandise from importation through to the export or destruction that supported the claim. CBP Form 7552 was abolished on February 24, 2019, when drawback shifted to the Trade Facilitation and Trade Enforcement Act (TFTEA) framework and electronic filing in the Automated Commercial Environment (ACE); the proof function it served now lives in the transfer record required by 19 CFR 190.10. Importers, manufacturers, distributors, and drawback specialists still refer to those records informally as "the 7552," but nothing is filed with CBP.

At a glance

• Full name: CBP Form 7552, Delivery Certificate for Purposes of Drawback.
• Current status: Abolished as of February 24, 2019; as of September 2026 the 19 CFR 190.10 transfer record applies instead. Confirm the current status before acting.
• Who prepared or used it: The transferor of the merchandise, who handed it to the party that would file the drawback claim.
• What replaced it: A transfer record maintained under 19 CFR 190.10 carrying eleven required data elements.
• When in the lifecycle: At each transfer of imported merchandise, substituted merchandise, or an article between parties in the drawback chain, before the claim is filed.
• System or channel: None. The record is kept in the party's own business records; drawback claims themselves are filed electronically in ACE.
• Governing authority: 19 CFR part 190, specifically 19 CFR 190.10.
• Retention: 3 years from liquidation of the related drawback claim.
• Related terms: CBP Form 7551, CBP Form 7553, CBP Form 301, CBP Form 7512.

Why CBP Form 7552 was abolished

CBP Form 7552 was abolished because the TFTEA drawback regime replaced certificate-based proof of transfer with a recordkeeping obligation that sits with the transferring party. Under the old system, the party that sold or moved merchandise to the eventual claimant executed a delivery certificate identifying the goods and the import entry behind them, and the claimant assembled those certificates into a paper chain supporting the claim. That worked when drawback claims were paper documents filed on CBP Form 7551, Drawback Entry, the paper drawback claim that was itself abolished with TFTEA drawback. Once claims became electronic filings in ACE under 19 CFR part 190, CBP no longer had a paper file into which a certificate could be slotted, and the agency shifted the burden to records that the parties create and hold themselves.

The practical difference is that CBP Form 7552 was a document you handed to somebody. The 19 CFR 190.10 transfer record is a document you create and keep, and produce only if CBP asks during claim review, desk review, or audit. Nothing about the underlying evidentiary question changed: CBP still needs to see that the quantity claimed traces back to a specific designated import line.

What the 19 CFR 190.10 transfer record must contain

The transfer record that replaced CBP Form 7552 must carry eleven data elements under 19 CFR 190.10. Those elements are: the recipient of the merchandise; the delivery date; the import entry and line number; the quantity transferred; the duties, taxes and fees attributable to it; the import date; the port; the source party; a description of the merchandise; the 10-digit HTSUS number; and, where substitution applies, the substituted HTSUS number. You can find the applicable 10-digit numbers in the Harmonized Tariff Schedule of the United States.

Format is not prescribed the way a form is prescribed. A spreadsheet, an ERP extract, a commercial invoice annotated with the required fields, or a document that still looks like the old CBP Form 7552 layout can all work, provided every one of the eleven elements is present and accurate. Many companies kept the 7552 template precisely because it already prompted for most of the fields, which is why the name persists in the trade.

Retention

Records supporting a transfer that would once have been evidenced by CBP Form 7552 must be retained 3 years from liquidation of the related drawback claim. Note that the clock runs from liquidation of the claim, not from the date of the transfer or the date of export, so a transfer record can sit alive in your files for years after the physical movement occurred. General customs recordkeeping exposure is a separate matter; see our note on recordkeeping penalties under 19 USC 1509.

Who is responsible for the transfer record and when

Responsibility for the record that replaced CBP Form 7552 sits with the party transferring the merchandise, and the claimant is the party that needs it to survive review. In a typical chain, an importer of record buys goods, sells or ships them to a processor or distributor, and that party or a downstream party exports or destroys them and files the drawback claim in ACE. Each link where title or possession moves is a transfer that needs a record. The claimant should collect copies as a commercial condition of the transaction, because a claimant that cannot produce the chain when CBP asks is in the same position as a claimant that never had a delivery certificate under the old CBP Form 7552 regime.

Timing matters. Build the record at the time of transfer, when the import entry and line, quantity, and duty amounts are still easy to pull. Reconstructing eleven data elements two years later from a warehouse transfer log is where most claims come apart.

Common CBP Form 7552 and transfer record failures

The failures CBP sees on records that replaced CBP Form 7552 cluster into three patterns. First, incomplete transfer records: the document names the parties and the quantity but omits the import entry and line, the duties, taxes and fees, or the substituted HTSUS number, and therefore does not meet 19 CFR 190.10. Second, quantities that do not tie to the designated import line: the claim designates a line for a quantity larger than the transfer record supports, or units of measure differ between the entry summary and the transfer document. Third, records held by the wrong party: the transferor keeps the only copy and the claimant, who is the one CBP asks, cannot produce it.

The cost of these failures is denial or reduction of the claim, and potential recovery of drawback already paid. Because accelerated payment is bonded, a denial can also reach the surety obligation on CBP Form 301, Customs Bond, the single transaction or continuous surety bond securing duties, taxes, fees and compliance obligations to CBP under 19 CFR part 113.

How CBP Form 7552 relates to other drawback and customs forms

CBP Form 7552 belongs to a small family of drawback documents, and confusing it with its neighbors is a common error. CBP Form 7551, Drawback Entry, was the paper drawback claim, also abolished with TFTEA drawback; claims are now filed electronically in ACE under 19 CFR part 190, and we cover that transition in our article on CBP Form 7551. CBP Form 7553, Notice of Intent to Export, Destroy or Return Merchandise for Purposes of Drawback, is the notice that lets CBP examine goods before export or destruction supporting a claim; it is alive and distinct from CBP Form 7552 in both purpose and timing.

Other forms touch the same merchandise without serving the drawback proof function. CBP Form 7512, Transportation Entry and Manifest of Goods Subject to CBP Inspection and Permit, is the in-bond application for moving unentered goods under bond as an IT, T&E, or IE movement, and is now electronic; see our in-bond explainer. CBP Form 214, Application for Foreign-Trade Zone Admission and/or Status Designation, admits merchandise into an FTZ and elects zone status (privileged foreign, nonprivileged foreign, domestic, or zone-restricted), while CBP Form 216, Application for Foreign-Trade Zone Activity Permit, requests CBP approval to manipulate, manufacture, exhibit or destroy merchandise inside a foreign-trade zone. Neither is an FTZ Board filing and neither substitutes for a drawback transfer record.

Further afield, CBP Form 3311, Declaration for Free Entry of Returned American Products, supports duty-free return of U.S.-origin goods under HTSUS 9801.00.10 (19 CFR 10.1); CBP Form 4455, Certificate of Registration, registers identifiable goods by serial number or marks with CBP before export for duty-free return under Chapter 98; CBP Form 3299, Declaration for Free Entry of Unaccompanied Articles, covers personal and household effects arriving separately from a traveler; and CBP Form 7523, Entry and Manifest of Merchandise Free of Duty, Carrier's Certificate and Release, is a paper entry for low-value duty-free goods that also functions as a carrier release and small-vehicle inward manifest. None of these replaces the CBP Form 7552 function.

Frequently asked questions

Is CBP Form 7552 still accepted by CBP?

No. CBP Form 7552 was abolished on February 24, 2019, and as of September 2026 the transfer record under 19 CFR 190.10 is what CBP looks for. Some companies still use a 7552-style layout as an internal template, which is acceptable as long as all eleven data elements are present. Confirm the current status with CBP before relying on any form-based approach.

Do I file the CBP Form 7552 replacement record with CBP?

No. Unlike CBP Form 7552, which was physically handed to the claimant, the 19 CFR 190.10 transfer record is maintained by the transferor and produced on request. The drawback claim itself is filed electronically in ACE.

How long must records replacing CBP Form 7552 be kept?

Transfer records that replaced CBP Form 7552 must be retained 3 years from liquidation of the related drawback claim. Because liquidation of a drawback claim can occur well after the transfer, plan retention around the claim, not the shipment.

What happens if a transfer record is missing an element?

A record that would once have been a CBP Form 7552 but omits one of the eleven data elements may not satisfy 19 CFR 190.10, and CBP can reduce or deny the associated claim. Fix gaps before filing rather than during review.

What importers and brokers should do

• Audit your current transfer documentation against the eleven data elements in 19 CFR 190.10 and remediate any template that is still a straight copy of the abolished CBP Form 7552 without the added fields.
• Write transfer record delivery into purchase and sale terms so the claimant holds a copy at the time of transfer, not after a CBP inquiry.
• Reconcile transferred quantities to the designated import entry line and unit of measure before the claim is transmitted in ACE.
• Set retention triggers off liquidation of each drawback claim, holding records 3 years from that date.

Key references

• 19 CFR 190.10: the transfer record rule that replaced CBP Form 7552, including the required data elements and retention.
• 19 CFR part 190: the full TFTEA drawback regulations governing claims filed in ACE.
• CBP drawback program page: CBP guidance on drawback filing and requirements.
• Harmonized Tariff Schedule of the United States: source for the 10-digit HTSUS and substituted HTSUS numbers required in the transfer record.
• CBP forms library: current CBP forms, including CBP Form 7553 and CBP Form 301.