Answer first
Core rule
Only the person primarily liable for duties may withdraw bonded merchandise: the importer of record on the warehouse entry, an actual owner with the required declaration and superseding bond, or a transferee that received withdrawal rights under Part 144 Subpart C. Consumption withdrawal uses Form 7501 or its electronic equivalent; direct or indirect exportation generally uses a Part 18 in-bond application; transportation to another port is allowed only when final consumption or export withdrawal can be completed there before the warehousing period expires. Merchandise is not released merely because a withdrawal was filed: the approved permit evidences CBP authorization. Current law was reviewed on 2026-08-18 against the eCFR text current through 2026-08-14. For the October 2026 CBLE, answer from the exam-designated 2025 CFR edition when its wording or numbering differs from live law.
Authority and lookup route
Locate the rule before returning to the facts. Links point to government or official publications.
Reference lookup task
Find the three persons who may have the right to withdraw, then map consumption, exportation, and transportation to §§144.36-144.38.
Route: Begin at §144.31, then read the headings and opening paragraphs of §§144.36, 144.37, 144.38, and finish at the permit rule in §144.39.
Worked example
Company T bought bonded merchandise from the warehouse-entry importer, but no transfer of withdrawal rights was completed under Part 144 Subpart C. T files a consumption withdrawal on Form 7501. May T withdraw solely because it owns the goods commercially?
- 1Start with §144.31 rather than commercial title alone.
- 2Identify the warehouse-entry importer as the person primarily liable unless another listed route applies.
- 3Check for an actual-owner declaration and superseding bond or a valid transfer of withdrawal rights.
- 4Reject T's withdrawal because the facts establish neither alternative.
Conclusion: No. Commercial ownership alone does not place T within a §144.31 category; withdrawal rights must be established through one of the listed regulatory routes.
Common traps
- Equating commercial ownership with the regulatory right to withdraw.
- Using a consumption withdrawal form for an indirect export movement without checking Part 18.
- Moving merchandise to another port when final withdrawal cannot occur before the warehouse period expires.
- Treating a filed withdrawal as CBP authorization without the approved permit.