ACE FD12 and FD13: new Section 232 manufacturing drawback validations
Two new ACE error codes gate manufacturing drawback on eligible Section 232 auto and truck parts duties. Here is what FD12 and FD13 reject, and how to file cleanly.
On April 21, 2026, CBP deployed two new ACE drawback error validations, FD12 and FD13, into the Production environment. The change is not a rehash of the older steel and aluminum Section 232 substitution limits. It is a filing gate for manufacturing drawback on specific Section 232 auto and truck parts.
CSMS #68402148 states that the validations support proclamations covering Medium- and Heavy-Duty Vehicle Parts (MHDVPs) and Automobile Parts that are products of South Korea. The claims in scope are Direct Identification Manufacturing Drawback under 19 U.S.C. § 1313(a) and Substitution Manufacturing Drawback under 19 U.S.C. § 1313(b).
If you manufacture with eligible 232-covered parts and export a different article, these codes now decide whether ACE will accept the 232 portion of the claim. If you only file unused or rejected merchandise drawback on steel or aluminum 232 lines, this CSMS is not your primary control. Keep that distinction clear when you update SOPs.
What changed in ACE PROD on April 21, 2026
CBP first put the validations into ACE CERT on March 17, 2026 under CSMS #68087488, then moved them to PROD on April 21, 2026. The CERT message is useful because it states the policy intent more plainly: ACE now allows manufacturing claims for the specific eligible Section 232 auto and truck part tariffs under § 1313(a) and § 1313(b), while blocking overclaims and ineligible 232 combinations.
That is a narrower opening than a blanket "Section 232 is drawback-eligible" rule. The proclamations and the ACE validations travel together. Eligibility still depends on the proclamation text for the product set. ACE then enforces claim date, HTS pairing, and available duty money on the entry summary line.
These validations apply to manufacturing drawback under 19 U.S.C. § 1313(a) and 19 U.S.C. § 1313(b) for eligible MHDVP and South Korea automobile parts Section 232 duties. They are separate from the Library article on Section 232 steel and aluminum substitution limits.
FD12: 232 CLM NOT ALLOWED
ACE returns FD12 232 CLM NOT ALLOWED when the claim date on a § 1313(a) or § 1313(b) claim is before November 1, 2025.
In practice, that means manufacturing claims that try to pull eligible 232 auto or truck part duties for a claim dated before the November 1, 2025 threshold will fail validation. Do not treat this as a soft warning. Fix the claim date logic in your drawback system, or exclude the ineligible 232 money before transmit.
Teams that backdate claim construction, or that reuse templates built for pre-November 2025 manufacturing windows, are the most likely to hit FD12. Confirm how your software stamps claim date before you blame the entry data.
Triggers when the claim date of a § 1313(a) or § 1313(b) drawback claim is before November 1, 2025.
Source: CSMS #68402148 (PROD, Apr 21, 2026); CSMS #68087488 (CERT, Mar 17, 2026).
FD13: EXCESS 232 DTY CLMD
ACE returns FD13 EXCESS 232 DTY CLMD in two related situations described by CBP:
- Missing HTS pair: the § 1313(a) or § 1313(b) claim is not reported with both the eligible 232 HTS number and the Chapter 1-97 HTS number.
- Overclaim: the requested claim amount exceeds the available money on the entry summary line.
The HTS pairing rule should look familiar if you already file Section 301 claims. Trade-remedy drawback filing has long required both the Chapter 99 (or other remedy) HTS and the underlying Chapter 1-97 classification. FD13 brings that discipline to these eligible 232 manufacturing claims and adds an available-funds check.
Operationally, that means your claim extract must preserve the relationship between the eligible 232 tariff line and the Chapter 1-97 product line on the same entry summary context. If your model collapses those into one synthetic line, or claims more 232 duty than remains available on the line, ACE will reject.
Triggers when the § 1313(a)/(b) claim lacks both the eligible 232 HTS# and the Chapter 1-97 HTS#, or when the requested amount exceeds available money on the entry summary line.
Source: CSMS #68402148.
How this differs from steel and aluminum Section 232 substitution limits
Drawback filers often compress "Section 232" into one mental bucket. That is unsafe.
Steel and aluminum Section 232 treatment has been shaped by proclamations that historically barred drawback on those 232 duties, with later, product-specific openings that still do not create a free substitution path for every claim type. The existing Library article on Section 232 substitution limits covers that steel and aluminum story.
FD12 and FD13 are different. They are ACE validations that enable and police manufacturing drawback for specific auto and truck parts 232 duties under § 1313(a) and § 1313(b). If your internal memo says "232 never recoverable," update it. If it says "all 232 is now recoverable by substitution," update it the other direction. The correct statement is product-set specific and claim-type specific.
FD12 and FD13 are manufacturing-claim gates for eligible auto and truck parts 232 duties, not a rewrite of steel and aluminum substitution rules.
What importers and brokers should do now
1. Re-map eligible product sets
Identify imports that paid Section 232 on Medium- and Heavy-Duty Vehicle Parts or on Automobile Parts that are products of South Korea. Confirm the proclamation coverage and the HTS actually used on the entry. Do not assume every Chapter 99 232 line in your auto supply chain is in scope.
2. Limit the claim path to manufacturing
These validations are framed around § 1313(a) and § 1313(b). If your program is unused merchandise only, do not force 232 auto or truck part duties into that path just because FD12 and FD13 exist. Match the claim provision to the proclamation allowance.
3. Enforce the claim-date floor
Encode November 1, 2025 as a hard floor for claim dates on these manufacturing claims. Reject or strip the 232 component earlier in your QA if the claim date is before that date.
4. Preserve both HTS numbers and available duty
Transmit both the eligible 232 HTS and the Chapter 1-97 HTS. Reconcile requested 232 drawback to remaining available money on the entry summary line after prior claims, liquidations, and adjustments.
5. Refresh the error dictionary and client messaging
CBP pointed filers to the updated Drawback Error Dictionary in the Supporting Documentation section of the ACE ABI CATAIR materials on cbp.gov. Update broker rejection playbooks so FD12 and FD13 are explained in plain language to clients, not only as code dumps.
Questions and contacts
CSMS #68402148 directs questions to OTDrawback@cbp.dhs.gov or your Client Representative. Use that channel for ACE validation behavior. Keep product-eligibility questions tied to the governing proclamation text and entry line facts.
QA tests to add before PROD transmit
- Claim provision is § 1313(a) or § 1313(b) when 232 auto/truck part duties are included.
- Claim date is on or after November 1, 2025.
- Each claimed 232 line carries the eligible 232 HTS and the Chapter 1–97 HTS.
- Requested 232 amount is less than or equal to remaining available money on the entry summary line.
- Product set matches MHDVP or South Korea automobile parts coverage under the governing proclamation.
If any test fails, strip the 232 component or correct the claim before ACE sees it. Catching FD12 or FD13 in pre-validation is cheaper than repairing a rejected manufacturing package after export evidence has already been assembled.
- FD12 and FD13 deployed to ACE PROD on April 21, 2026 for manufacturing drawback under 19 U.S.C. § 1313(a) and § 1313(b).
- FD12 blocks claims dated before November 1, 2025.
- FD13 requires both the eligible 232 HTS and the Chapter 1-97 HTS, and blocks overclaims against available entry-line money.
- Scope is eligible MHDVP and South Korea automobile parts Section 232 duties, not a general steel/aluminum substitution rewrite.
- Contact OTDrawback@cbp.dhs.gov or your Client Representative for validation questions.
- CSMS #68402148 - New ACE Drawback Error Validations Set to Deploy to PROD April 21, 2026 · U.S. Customs and Border Protection
- CSMS #68087488 - New ACE Drawback Error Validations Deployed to ACE CERT Environment March 17, 2026 · U.S. Customs and Border Protection
- ACE Drawback Error Dictionary · U.S. Customs and Border Protection
- 19 U.S. Code § 1313 - Drawback and refunds · Legal Information Institute
This article is for general information and is not legal or tax advice. Drawback eligibility depends on your specific facts, and final refunds are determined by CBP at liquidation. Consult a licensed customs broker or attorney for your situation.