Is Section 301 Duty Refundable for Footwear Importers?

Please read: this guide is general information, not legal or customs advice, and rates and examples are illustrative. Drawback claims must be completed within 5 years of the date of importation (19 U.S.C. 1313(r)). Destruction claims require destruction under CBP supervision with advance notice, and DrawbackIQ currently prepares unused-merchandise export claims only. Your licensed customs broker decides what can be filed.

Yes. Section 301 tariffs imposed on footwear (and components) imported from China are eligible for drawback under the statute. This is one of the most significant opportunities for footwear importers to recover unclaimed duties, especially given the scale of Section 301 tariffs on footwear entering the US.

Section 301 and Footwear: The Numbers

The US has collected over $9 billion in Section 301 tariffs on Chinese footwear since 2018. These are additional tariffs on top of the base ad valorem duty. For a footwear importer, Section 301 often comprises 5 to 40 percent of total duties paid, depending on the specific tariff rate and product classification.

Under 19 U.S.C. 1313, Section 301 duties are eligible for refund on the same basis as regular duties: when the imported merchandise is exported or destroyed. Most importers do not pursue these refunds because they do not realize the tariffs are recoverable, or they assume the claim process is too complex. It is neither.

Example: Section 301 Impact on Refunds

A footwear importer enters $2 million annually with an average combined duty rate of 18 percent (12 percent base plus 6 percent Section 301). If 20 percent is exported over 5 years, the estimated refund is approximately $356,400. Without Section 301 refund eligibility (base only), it would be $237,600. Section 301 accounts for over $118,000 in this example.

How Section 301 Refunds Work

Your broker includes Section 301 duty amounts in the claim package on the same line items as base duties. The CBP (Customs and Border Protection) refunds Section 301 duties using the same matching logic as base duties: direct identification of exported merchandise, or substitution basis matching on HTS codes. There is no separate process or delay; it is part of a single drawback claim.

Tariff Timing and the 5-Year Lookback

Section 301 tariffs on footwear have been in effect since September 2018. The 5-year lookback window means you can file claims on footwear entering from September 2019 forward (measured from today). This is a substantial volume of inventory for most importers.

Documentation and Proof of Export

Filing a Section 301 refund claim requires the same documentation as any duty drawback claim: entry records (which CBP has), and proof of export or destruction (which comes from your supply chain). If your footwear is exported through regular commercial channels or via Amazon international fulfillment, you have the proof. Our engine matches it to your imports automatically.

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Disclaimer

DrawbackIQ prepares claim packages for a licensed customs broker to file. DrawbackIQ is not a customs broker. This page is informational only. Tariff laws are complex; consult your broker or customs attorney for advice specific to your imports.