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Section 232 UAS duties: Chapter 99 filing and manufacturing drawback rules

CSMS #69738151 implements Section 232 UAS and UAS component duties. Filing headings, partner rates, FTZ privileged foreign status, and when manufacturing drawback is available.

Cover illustration: Section 232 UAS duties: Chapter 99 filing and manufacturing drawback rules

Proclamation 11055 (August 13, 2026) imposes additional Section 232 duties on certain Unmanned Aircraft Systems (UAS) and UAS components. CSMS #69738151 is CBP's filing guide. The FR cite is 91 FR 53699.

For goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on September 3, 2026, filers must report the applicable Chapter 99 heading in 9903.08.20 through 9903.08.26. A further expansion under 9903.08.22 for additional components takes effect February 9, 2027, at 25%.

Manufacturing drawback under 19 U.S.C. 1313(a)-(b) is available for these 232 duties only when the article clears the AD/CVD, Trade Agreement Partner, and 85% content tests.

Chapter 99 headings and rates

CSMS maps the additional ad valorem rates as follows (except as provided in later partner or onshoring headings):

  • 9903.08.20: 0% (articles in enumerated provisions of subdivision (c) of U.S. note 43 not for use in or with the products described therein).
  • 9903.08.21: 100% (unmanned aircraft, docking stations/parts, heavier UAS parts/components, and UAS with thermal imaging, as provided in subdivisions (c)(1)-(3)).
  • 9903.08.22: 25% (unmanned aircraft without thermal imaging under subdivision (c)(4); expands Feb. 9, 2027 to cover additional parts/components under (c)(5)).
  • 9903.08.23: 10% (products of the United Kingdom). Do not report until further guidance.
  • 9903.08.24: 15% combined column one and Section 232 rate (Japan, Liechtenstein, South Korea, Switzerland, Taiwan, or an EU member). Do not report until further guidance.
  • 9903.08.25: 0% (onshoring plan approved by DHS or the Department of War; expires February 9, 2027).
  • 9903.08.26: 0% (onshoring plan approved by the Secretary of Commerce). Do not report until further guidance.
Effective: Sep. 3, 2026 (initial) · Feb. 9, 2027 (expansion)
Headings: 9903.08.20–9903.08.26
Hold reporting: 9903.08.23 · 9903.08.24 · 9903.08.26
CSMS #69738151 · 91 FR 53699 · Proclamation 11055

Covered Chapter 85 / 88 lines (examples from CSMS)

The CSMS lists Chapter 1–97 classifications under the note subdivisions, including docking and control gear (8504.40.9580, 8537.10.9170), unmanned aircraft headings in 8806, and parts in 8807.10.00 / 8807.20.00 / 8807.30.00 / 8807.90.90. Match the line to the correct subdivision before you pick the Chapter 99 heading. Wrong pairing is a duty and compliance problem, not a formatting nit.

Trade agreements, Chapter 98, and FTZ

For articles under 9903.08.21–9903.08.26 that are eligible for special tariff treatment under general note 3(c)(i) programs, the duties in these headings are collected in addition to any special rate otherwise applicable. Chapter 98 claims remain available on their own terms; AD/CVD and other duties continue. No Chapter 99 claim for a lower or free rate is allowed to undercut these additional duties based on information supplied by CBP.

FTZ: products described in Annex I, II, or III of Proclamation 11055 (except domestic status under 19 CFR 146.43) that are subject to the proclamation duty and admitted on or after the effective date must be admitted as privileged foreign status under 19 CFR 146.41, and will take the applicable ad valorem rates upon entry for consumption.

Manufacturing drawback: three conditions

CSMS states that manufacturing drawback claims under subsections (a) and (b) of section 313 of the Tariff Act of 1930, as amended (19 U.S.C. 1313(a)-(b)), shall be available with respect to the duties imposed pursuant to Proclamation 11055 on articles that meet all of the following:

  • (a) Not AD/CVD merchandise type: the article is not of a type of merchandise subject to an antidumping or countervailing duty order, without regard to whether the article is from the country or countries listed in the order.
  • (b) Trade Agreement Partner origin: the article is a product of Trade Agreement Partners: United Kingdom, European Union, Japan, Republic of Korea, Switzerland, Liechtenstein, Mexico, Canada, and any trading partner with which the United States concludes a trade and security agreement.
  • (c) 85% partner content: at least 85 percent of the content of the article is a product of Trade Agreement Partners.
Drawback desk check

Quote the CSMS manufacturing-drawback paragraph as published. Do not assume unused merchandise or substitution theories are covered by that sentence. Build the claim file around 1313(a)-(b), partner origin, the 85% content workpapers, and a clean AD/CVD merchandise-type screen. Filing questions: TradeRemedy@cbp.dhs.gov.

Key takeaways
  • Section 232 UAS duties under Proclamation 11055: report 9903.08.20–9903.08.26 for consumption entries on/after Sep. 3, 2026; 9903.08.22 expands Feb. 9, 2027.
  • Rates vary by heading: 0%, 100%, 25%, 10%, 15% (combined), or 0% onshoring; do not report 9903.08.23, .24, or .26 until further guidance.
  • FTA/preference goods still owe these additional duties on top of special rates; FTZ admissions take privileged foreign status.
  • Manufacturing drawback (19 U.S.C. 1313(a)-(b)) available only if not AD/CVD merchandise type, Trade Agreement Partner product, and ≥85% partner content.
  • Contact: TradeRemedy@cbp.dhs.gov; primary CSMS #69738151; FR 91 FR 53699.
Primary sources
  1. CSMS #69738151 - GUIDANCE: Section 232 Duties on Imports of Unmanned Aircraft Systems and Unmanned Aircraft Systems Components · U.S. Customs and Border Protection
  2. Adjusting Imports of Unmanned Aircraft Systems and Unmanned Aircraft Systems Components Into the United States (91 FR 53699) · Federal Register
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DrawbackAI Team
We build software for the US duty drawback program — so the refund isn't reserved for billion-dollar importers and the firms that charge 30% to find it.

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.

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