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Regulatory · 8 min

Section 232 UAS filing guide: HTSUS 9903.08.20–9903.08.26 and drawback

CBP entry-filing CSMS for Section 232 UAS and UAS components: heading rates, hold-reporting lines, manufacturing drawback carve-out, and privileged foreign FTZ status.

Cover illustration: Section 232 UAS filing guide: HTSUS 9903.08.20–9903.08.26 and drawback

CBP's filing guide for Section 232 duties on Unmanned Aircraft Systems (UAS) and UAS components is CSMS #69738151 (Sept 2, 2026). It implements Proclamation 11055 (Aug 13, 2026; 91 FR 53699). Filers report Chapter 99 headings 9903.08.20 through 9903.08.26 for covered Chapter 85 / 88 merchandise.

The Library already covers the same CSMS in Section 232 UAS duties: Chapter 99 filing and manufacturing drawback rules. Use that for narrative background. Use this piece as the broker filing map: rates, hold-reporting headings, manufacturing drawback carve-out, and FTZ privileged foreign status.

Effective 12:01 a.m. ET Sept 3, 2026 (and Feb 9, 2027 for certain components). Rates run 0% / 10% / 15% combined / 25% / 100%. Hold reporting on 9903.08.23, .24, and .26 until further guidance. Manufacturing drawback is available only under narrow conditions.

Effective dates

Proc. 11055 · 91 FR 53699 · CSMS #69738151
Initial duties: goods entered/withdrawn on or after 12:01 a.m. ET Sept 3, 2026
Component expansion under 9903.08.22 (c)(5): on or after 12:01 a.m. ET Feb 9, 2027
9903.08.25 onshoring heading expires Feb 9, 2027

Chapter 99 heading map (from CSMS #69738151)

  • 9903.08.20: 0% additional. Articles in enumerated provisions of subdivision (c) of U.S. note 43 that are not for use in or with the products described therein.
  • 9903.08.21: 100% additional (except as provided in 9903.08.23–.26). Unmanned aircraft, docking stations/parts, heavier UAS parts/components under (c)(1)–(2), and UAS with thermal imaging under (c)(3).
  • 9903.08.22: 25% additional (except as provided in 9903.08.23–.26). Unmanned aircraft without thermal imaging under (c)(4). From Feb 9, 2027, also covers additional parts/components under (c)(5), except those already under (c)(2).
  • 9903.08.23: 10% additional (products of the United Kingdom). Do not report until further guidance.
  • 9903.08.24: 15% additional ad valorem rate (combined column one and Section 232 duty rate) for Japan, Liechtenstein, South Korea, Switzerland, Taiwan, or an EU member. Do not report until further guidance.
  • 9903.08.25: 0% additional for companies with an onshoring plan approved by DHS or the Department of War. Expires Feb 9, 2027.
  • 9903.08.26: 0% additional for articles subject to a Commerce-approved onshoring plan (process via future FR notice). Do not report until further guidance.
Rate hygiene

For 9903.08.24, CSMS labels the rate as a combined column one and Section 232 duty rate. Do not stack column one again on top of that combined figure once reporting is authorized. Hold 9903.08.23, .24, and .26 until CBP says otherwise.

Covered Chapter 85 / 88 lines (examples)

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 statistical line to the correct subdivision before you pick the Chapter 99 heading.

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) 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 or orders.
  • (b) The article is a product of Trade Agreement Partners, composed of the United Kingdom, the European Union, Japan, the Republic of Korea, Switzerland, Liechtenstein, Mexico, Canada, and any trading partner with which the United States concludes a trade and security agreement.
  • (c) At least 85 percent of the content of the article is a product of Trade Agreement Partners.
Do not over-read the carve-out

This is manufacturing drawback only under 1313(a)-(b), and only when AD/CVD-type, partner-origin, and 85% content tests all clear. It is not a general unused-merchandise or substitution free-for-all for every UAS 232 line. If any condition fails, treat the 232 duty as non-recoverable for this proclamation path.

Section 232 entry-filing questions: TradeRemedy@cbp.dhs.gov. Entry-summary ACE errors: Client Representative or ACE Help Desk.

Key takeaways
  • CSMS #69738151 implements Proc. 11055 / 91 FR 53699 for UAS and UAS components via HTSUS 9903.08.20–9903.08.26.
  • Effective 12:01 a.m. ET Sept 3, 2026; 9903.08.22 expands Feb 9, 2027 for additional components under (c)(5). 9903.08.25 expires Feb 9, 2027.
  • Rates: 0% (.20, .25, .26), 100% (.21), 25% (.22), 10% UK (.23), 15% combined partner rate (.24). Do not report .23, .24, or .26 until further guidance.
  • FTA/preference special rates: 232 heading duties collected in addition. FTZ: privileged foreign status (19 CFR 146.41) unless domestic status.
  • Manufacturing drawback under 19 U.S.C. 1313(a)-(b) only if AD/CVD-type, Trade Agreement Partner origin, and ≥85% partner content all clear.
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 (Proclamation 11055; 91 FR 53699) · The White House
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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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