DRB · CBLE study guide
Drawback
Drawback types, claims, deadlines, records, privileges.
- 60past questions in CBLE Pass
- ≈3questions on a typical 80-question exam
- 19 CFR Part 190where the rules live
Common traps
Wrong answers on past exams cluster around a few beliefs. Here is each one, and what the rule actually says.
General manufacturing drawback rulings
“Letters of notification expire in 5 years, or packaging can't get drawback.”
The rule: A letter of notification to operate under a general ruling is filed with the drawback office concurrent with or before the first claim, if the ruling is followed without variation; it stays in effect indefinitely subject to 190.8(h).
Remember: File with drawback office; no fixed expiry; name changes go to the drawback office.
19 CFR 190.7 · 19 CFR 190.8(g)(2) · 19 CFR 190.8(h)
Notice of intent and examination timelines
“Notice deadlines are 15-60 days, and CBP has a week to examine.”
The rule: CBP Form 7553 is filed at least 5 working days before export (190.35(a)) or 7 working days before destruction (190.71). CBP decides within 2 working days whether to examine; if it examines, it does so within 5 working days of presentation, in-bond to the export port if needed (190.35(c)-(d)).
Remember: 5 export / 7 destroy / 2 decide / 5 examine.
19 CFR 190.35 · 19 CFR 190.71
Duties eligible for drawback
“Marking duties are 'ordinary customs duties'.”
The rule: Ordinary customs duties include liquidated duties, estimated duties, voluntary tenders, prior-disclosure tenders, and restored duties under 1592(d); marking duties are not listed.
Remember: Check the 190.3(a)(1) list.
19 CFR 190.3(a)
Drawback record retention
“Drawback records follow the 5-year rule or run from payment.”
The rule: Drawback records are retained 3 years after liquidation of the claim.
Remember: 3 years after liquidation.
19 CFR 190.15
Foreign territory for drawback
“Insular possessions or Puerto Rico are foreign territory.”
The rule: Guantanamo Bay is treated as foreign territory; shipments to USVI, American Samoa, Guam and similar possessions get drawback only under 1313(j)(1); Puerto Rico is in the customs territory.
Remember: Guantanamo = foreign.
19 CFR 190.5
Drawback fraud penalty
“The maximum is 1x, 5x or 20%.”
The rule: Fraud: up to 3 times the actual or potential loss of revenue; repetitive negligence: up to 1 times.
Remember: Fraud 3x.
19 CFR 190.62(b)
Try a past question
October 2026 CBLE, question 65
Jane Sibley, of Sibley Furniture Outlet, needs to destroy merchandise pursuant to an unused merchandise drawback claim under 19 USC 1313(j). Ms. Sibley filed a Notice of Intent to Export, Destroy, or Return Merchandise for Purposes of Drawback on CBP Form 7553, notifying CBP that she intends to destroy the merchandise on the seventh working day after CBP's receipt of her notice. By the date when the merchandise is set to be destroyed, Ms. Sibley had not received notice of CBP's decision to witness or not witness the destruction. Ms. Sibley proceeds with the destruction of the merchandise as scheduled, without a determination from CBP. Based on the facts above, which ONE of the following statements is TRUE?
Show the answer and why
A. Incorrect. If CBP doesn't respond within 4 working days, destruction may proceed without written approval (19 CFR 190.71(a)).
B. Incorrect. The destruction is deemed supervised, but the claimant must still submit evidence of destruction (190.71(b)).
C. Correct. Destruction means the goods have no commercial value, and can include material recovery (19 CFR 190.2).
D. Incorrect. Evidence must come from a disinterested party; CBP certifies CF 7553 only if it attends.
19 CFR 190.71 · 19 CFR 190.2 · law as of 2026-11-09
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