Free trade agreement claims on past entries: the indicator, the late-claim route and what a preference removes

How does a free trade agreement claim show up on an entry line?

As a prefix. General Note 3(c)(i) of the HTSUS lists each program under which special tariff treatment may be given and the symbol that marks it in the "Special" rate column. The same symbol goes in front of the 10-digit HTS number on the entry line: the CBP Form 7501 instructions (revision 02/26) put the special program indicator in column 31, directly below the line number and on the same line as the HTS number the rate is based on. No indicator means no claim, whatever the goods' origin and whatever certificates sit in a folder.

That makes the indicator the first column to read in an entry export. A line with origin in a partner country, a general rate above Free, a Special column that lists the partner's symbol and an empty indicator field is a line where duty was paid that may not have been owed. A line with an indicator is a claim someone has to be able to support.

USMCA has its own pages: unclaimed USMCA preference on past entries for the missed claim, and what CBP verifies on a USMCA certification for the claim that was made. This page covers all the US agreements side by side.

Which indicator, which late-claim route and which fee rule applies to each agreement?

The table pulls together four sources: the symbols in General Note 3(c)(i), the agreements named in 19 U.S.C. 1520(d), the fee exemptions in 19 CFR 24.23(c), and the Section 301 forced-labor headings in Chapter 99 for entries from July 24, 2026.

Two more indicators are worth recognising in old data. GSP's A, A+ and A* expired on December 31, 2020 and, according to CBP's GSP page, goods entered since January 1, 2021 pay the general rate while the program awaits renewal. And the per-country exclusion lists in note 52 take some subheadings out of the forced-labor duty for some partners, so check the line's own subheading before applying the rate in the last column.

What can you still claim after the entry was filed?

It depends on the agreement and on the date of importation.

1. The eight 1520(d) agreements. 19 U.S.C. 1520(d) lets CBP reliquidate to refund excess duties, including the merchandise processing fee, on goods that qualified under the Chile, Oman, Peru, Korea, Colombia, Panama, CAFTA-DR or USMCA rules of origin but were entered without the claim, if the importer files within one year after the date of importation with a declaration that the good qualified, copies of the certifications and any other documents CBP requires. The KORUS version in 19 CFR 10.1011 is typical: a declaration with the entry numbers and dates, the certification or other proof, a statement on who else received a copy of the entry summary, and a statement on any protest filed. CBP's CSMS 18-000612 says 1520(d) is the sole post-importation route for these agreements, regardless of liquidation, and that it goes through the ACE protest module or on paper, not a post-summary correction. CBP's PSC page lists the 1520(d) trade-agreement indicator among the data a PSC cannot change.
2. The other agreements. The same CSMS says a PSC is available for a post-importation preference claim when the program does not specify 1520(d). That covers Australia, Bahrain, Singapore, Israel, Jordan, Morocco and Japan, within the PSC window: 300 days from entry and at least 15 days before scheduled liquidation, whichever comes first. After liquidation, the route is not stated in CBP guidance for these agreements, and 19 CFR part 10 has no post-importation claim section for any of them, so confirm with your broker before relying on a protest under 19 U.S.C. 1514.
3. Past one year, for the 1520(d) agreements. The one-year limit runs from importation, not entry or liquidation. A line found after that is a process fix for the next entries.

Interest on a 1520(d) refund runs from the date of the claim to liquidation or reliquidation (19 U.S.C. 1505(c)), so the claim earns nothing for the months it was not filed. How to recover overpaid import duty puts these routes next to the others.

What does a preference remove from a stacked rate, and what does it leave?

A preference replaces the general rate with the special rate. It touches nothing else unless the Chapter 99 note for a measure says so, and most say the opposite.

The forced-labor row changes how much a preference is worth. For most partners, the 10 or 12.5 percent is added on top of whatever rate the line carries, so a claim still saves the full general rate. For Korea and Japan the headings work as a floor. Note 52(k) says that for headings 9903.05.49 (Japan) and 9903.05.71 (Korea), where the applicable column 1 rate is below 12.5 percent, the column 1 rate plus the additional duty totals 12.5 percent, and both headings show 12.5% in the Special column as well as the General column. On a low-rate Korean line, the total is 12.5 percent with or without the KR claim, and what the claim still saves is the fee. A JP claim on a low-rate line saves nothing at all, because Japanese goods do not get the fee exemption. One more interaction runs the other way: note 52(f)(1) takes articles under the Section 232 metal headings out of the forced-labor duty, so a metal article carries the Section 232 layer instead of it, with or without a preference. Why your entry shows the wrong duty stack shows how floors and add-ons are keyed on a line.

What is a missed or a valid claim worth on two lines?

Illustrative figures, both entered August 20, 2026, so the fiscal year 2026 fee limits apply (90 FR 34665).

Line A: cotton T-shirts from Colombia, HTSUS 6109.10.00, general rate 16.5 percent, Special "Free (CO)". Entered value $100,000.

A 1520(d) claim filed within a year of importation recovers the $16,500 and the $346.40 fee, with interest from the claim date. The $12,500 stays: no claim removes it.

Line B: plastic articles from Korea, HTSUS 3926.90.99, general rate 5.3 percent, Special "Free (KR)". Entered value $50,000.

Here a late KR claim is worth $173.20, not $2,650. Sorting missed claims by the general duty alone overstates Korean and Japanese lines entered from July 24, 2026; price each line on its own entry date with the duty calculator.

How do you audit preference claims across an entry export?

1. Missed claims. Filter lines whose origin is a partner country, whose subheading lists that partner's symbol in the Special column, and whose indicator is blank. Price each one with and without the claim, layer by layer, on its entry date.
2. Sort by deadline. For the eight 1520(d) agreements, the clock is one year from importation; for the others, the PSC window and then the protest window. Oldest first.
3. Check the evidence before anyone files. Origin on the 7501 is not proof that a good meets the agreement's rule of origin; the certification or other proof the claim regulation names is. Country of origin on past entries explains why the two can differ.
4. Check the claims that were made, too. A line with an indicator and no support underpaid duty, and the fee, and for USMCA goods since July 24, 2026 the Section 301 forced-labor duty as well. Each agreement's regulations require a prompt correction once the importer has reason to believe a claim is wrong; that goes to a broker or counsel as a correction or prior disclosure.
5. Check the fee. A valid claim under an exempting agreement should show no merchandise processing fee on that line; how the merchandise processing fee is calculated has the arithmetic.

TariffSense reads broker entry exports and entry summaries line by line and shows, for each line's entry date, the duty stack with and without the available preference, so missed claims are ranked by what they would actually return rather than by the general rate. The post-entry audit pillar covers the other line checks. The claims themselves are customs filings; confirm the route and the evidence with a licensed broker or trade counsel.