Key Takeaways:
- Aerospace suppliers can recover up to 99% of import duties paid on exported goods through a U.S. trade law provision called duty drawback.
- Section 301 duties on Chinese-origin goods and Section 232 duties on derivative articles are both eligible for drawback recovery.
- Claims can cover imports going back five years, meaning recoveries may reach as far back as 2021.
- Most qualified suppliers never file because the documentation process is complex, but specialized firms like CITTA handle it on contingency with no upfront cost.
- The five-year filing window closes on a rolling basis — every day of delay means older imports fall permanently outside eligibility.
The global aerospace supply chain is built on long supplier relationships, tight tolerances, and thin margins. Over the past several years, trade policy added sustained pressure to all three: raising landed costs, forcing sourcing decisions no one had planned for, and elevating trade compliance from a back-office function to a strategic discipline. For suppliers at every tier, absorbing higher import costs became a structural reality. What most suppliers never examined is whether those duties could come back.
Since 1789, a provision of U.S. trade law (19 U.S.C. 1313) has allowed companies to recover up to 99% of the duties, taxes, and fees they pay on imported goods. The mechanism is called duty drawback, and for aerospace suppliers who import components and export finished parts or assemblies, it is one of the few available tools to recover real dollars, strengthen margins, and build a cost structure that competitors still paying full duty cannot match.
For most, the claim has never been filed. The recovery is still sitting there, built up year by year as the tariff landscape intensified. Here’s what this industry absorbed.
Five Years of Accumulating Pressure
For most aerospace suppliers, the tariff burden didn’t feel like one thing. It felt like several, arriving in sequence, each from a different direction.
- Boeing-Airbus WTO tariff suspension (2021): The U.S. and EU agreed to suspend years of retaliatory tariffs on aerospace goods, offering brief relief for transatlantic suppliers. The reprieve did not last.
- Section 232, steel and aluminum: Tariffs on imported steel and aluminum held and rose throughout this period, now sitting at 50%. Suppliers dependent on specialty alloys and aerospace-grade aluminum felt the impact on raw material costs and margins at every tier.
- Section 301, Chinese-origin goods: Duties on electronics, machined parts, rare earth materials, and industrial inputs from China drove widespread China +1 sourcing strategies, pushing suppliers to diversify into Mexico, Vietnam, and Southeast Asia to reduce exposure.
- Reciprocal tariffs (2025): Expanded to roughly 70 countries. CBP collected $136 billion in import duties year-to-date, up 55% from $88 billion in 2024.
Redirected, Not Resolved
In early 2026, the Supreme Court struck down IEEPA tariffs, removing the legal basis for the administration’s broadest tariff authority. Section 122 duties, the follow-on measure, face active challenge at the Court of International Trade. For suppliers hoping the legal landscape would bring relief, the picture is more complicated.
The legal setbacks have not resolved the tariff environment. They have redirected it. Section 301 tariffs on Chinese-origin goods remain firmly in place and are widely expected to expand to additional countries through new USTR investigations. Many trade policy analysts predict the Trump administration will use expanded Section 301 authority, which rests on firmer legal ground than IEEPA, to effectively recreate the tariff levels that existed before the Supreme Court’s ruling. Section 232 on steel and aluminum, now at 50%, shows no signs of retreat.
For aerospace suppliers with global supply chains, import duties remain a structural feature of the operating environment. And for those who imported and exported during this period, the cost of inaction is recoverable. That is the part most programs missed.
Who Qualifies, and for What
Three drawback types are most relevant to aerospace parts suppliers.
Manufacturing drawback applies when a supplier imports materials or components (titanium stock, aluminum alloys, electronic subassemblies, specialty polymers, fastener blanks) and incorporates them into finished parts or assemblies that are subsequently exported. The duties paid at import are recoverable, triggered by the export of the finished product.
Unused merchandise drawback applies when imported goods are exported in substantially the same condition as imported, a provision relevant for suppliers managing excess inventory or cancelled orders.
Rejected goods drawback covers imported merchandise that fails inspection or does not conform to specifications and is returned to origin.
Both unused merchandise and rejected goods drawback are particularly applicable to aerospace MRO (maintenance, repair, and overhaul) operations, where imported components may go unused or be returned as non-conforming at meaningful frequency, making it an area where drawback claims have historically gone unfiled. For a deeper look at how drawback applies to aviation MRO operations specifically, including how CBP defines exportation and what that means for documentation, see CITTA’s guide to drawback for maritime and aviation operations.
In each case, claims must be filed within five years of the original import date. Top drawback providers handle this work on a contingency basis, meaning there is no fee unless a recovery is made. No risk, no retainer, no upfront investment of any kind.
Which Import Duties Are Recoverable
Not all import duties carry the same drawback eligibility, and the rules shifted significantly in April 2026. For aerospace suppliers, the recovery picture now looks like this:
- Section 301 duties on Chinese-origin goods are fully drawback-eligible, making them the most significant recovery opportunity for most aerospace suppliers. This covers electronics, machined parts, rare earth materials, and specialty components sourced from China.
- A significant policy shift took effect with the April 2, 2026 Presidential Proclamation: Section 232 duties on derivative articles are now eligible for manufacturing drawback. This covers metal-intensive manufactured products classified under HTSUS Chapters 84 and 85, including aerospace components and machined parts that many suppliers had long considered outside the scope of drawback.
- MFN (most-favored-nation) duties apply to a wide range of imported inputs used in aerospace manufacturing and have been in place for decades. Where these duties were paid on imported materials that ended up in exported products, they are drawback-eligible.
A Note on Section 232 Derivatives
The Section 232 derivative eligibility comes with conditions: no active antidumping or countervailing duty orders on the product; origin from a Trade Agreement Partner (EU, UK, Japan, South Korea, Canada, or Mexico); and metal content melted and poured or smelted and cast in that partner country. Suppliers sourcing from European or Asian trade partners, or from Mexico under USMCA, including those who nearshored as part of a China +1 strategy, should assess whether this new eligibility applies to their specific import profile.
The specific HTS classification of each product and its supplier origin determine eligibility. No assumption should substitute for a proper analysis.
The Five-Year Window Is the Critical Variable
Drawback claims can be filed on imports going back five years from the date of importation. For an aerospace supplier operating today, that window extends to 2021, covering the full escalation of Section 301 on Chinese-origin goods and multiple cycles of Section 232 adjustment, not to mention the regular duties that have been in place for decades.
A precision machined parts manufacturer that has been importing Chinese-origin aluminum and exporting finished structural components has likely accumulated a recoverable drawback position it has never quantified. The same applies to fastener manufacturers incorporating imported specialty alloys into exported assemblies, and interior components suppliers exporting seat structures or cabin panels into foreign aircraft programs.
Once a privileges application is submitted, claims can begin filing immediately — CBP’s processing timeline does not affect your ability to protect entries. What does matter is the five-year clock running from the date of each importation. The suppliers who act now capture the full window. Those who wait watch the oldest, most valuable entries expire permanently.
Why Most Claims Never Get Filed
The barriers are real. A manufacturing drawback claim requires documented linkage between specific import entries, production records, and export documentation, across a five-year window that often spans systems and counterparties never built to work together. Most qualified suppliers don’t file because the coordination appears insurmountable without dedicated infrastructure.
It is manageable, but only with drawback-specific expertise, established documentation processes, and an active CBP relationship. Getting the chain of custody right from the start is the difference between a clean claim and a denial. The aerospace suppliers acting now are the ones capturing the full recovery.
The Money Is Yours. Here’s How to Get It Back.
If your company has imported materials or components and exported finished products incorporating those materials at any point in the last five years, a drawback position almost certainly exists. Every day that passes, the oldest entries move closer to the five-year filing deadline. Once that window closes, those refunds are gone permanently.
Your next steps are straightforward:
- Use CITTA’s Drawback Calculator to estimate your recovery potential based on your import and export activity.
- Schedule a free discovery call. CITTA’s specialists will evaluate your specific position, covering import origins, export flows, and tariff categories, to identify what’s claimable.
- Get a comprehensive analysis with no upfront cost and no obligation. CITTA works exclusively on contingency: we only succeed when you do.
The duties are paid. The window is open. Start with our Drawback Calculator or schedule a free discovery call to find out what your company has left on the table, and how much of it is still recoverable.
Frequently Asked Questions
What is duty drawback?
- Duty drawback is a provision under 19 U.S.C. 1313 that lets companies recover up to 99% of import duties paid on goods that are later exported. It has been part of U.S. law since 1789.
Which aerospace suppliers qualify for duty drawback?
- Suppliers that import materials or components and export finished parts or assemblies are the most common candidates. MRO operations that deal with unused or rejected imported goods may also be eligible.
Are Section 301 tariffs on Chinese-origin goods recoverable through drawback?
- Yes, Section 301 duties are fully drawback-eligible. This covers electronics, machined parts, rare earth materials, and specialty components sourced from China.
What changed for Section 232 derivative drawback eligibility in 2026?
- A Presidential Proclamation dated April 2, 2026 made Section 232 duties on derivative articles eligible for manufacturing drawback. This opened up significant recovery potential for suppliers of metal-intensive aerospace components classified under HTSUS Chapters 84 and 85.
How far back can aerospace suppliers file drawback claims?
- Claims can be filed on imports going back five years from the original import date. For suppliers acting today, that window extends back to 2021, covering the full escalation of Section 301 and multiple Section 232 adjustment cycles.
Why do most eligible companies never file?
- The documentation requirements are demanding, requiring a clear, auditable link between import entries, production records, and export documents across several years and multiple systems. A specialized drawback provider makes this manageable.
What does it cost to work with CITTA on a drawback claim?
- CITTA works exclusively on contingency, meaning there is no fee unless a recovery is made. There is no retainer, no upfront cost, and no financial risk to the supplier.
