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Duty Drawback Simplification: What You Need to Know

After 12 years of consistent effort on the part of Customs and Trade, The Trade Facilitation and Trade Enforcement Act of 2015 was passed into law and signed by the President on February 24, 2016. This law will become effective on February 24, 2018. At that point, there will be a one year transition period where drawback claimants may file drawback claims under the new law or under the old law. However, on February 24, 2019, all drawback claims must be filed using the new duty drawback law. The duty drawback regulations have not yet been written.

The following are some of the main highlights of this new law:

  • Drawback claims will be matched based on 8-digit HTS substitution rather than commercial interchangeability. However, if the 8-digit classification starts with “other”, then the matching will be based on 10-digit HTS classification.
  • Drawback time frames will be 5 years from import to filing a drawback claim.

  • Drawback record keeping will be pushed out further from 3 years from payment of the drawback claim to 3 years from liquidation of the drawback claim.
  • Claims on MPF and HMF will be available for manufacturing drawback in addition to unused drawback.
  • The requirement for Certificates of Delivery will be removed and business records kept in the normal course of business will be used to track these transfers.

  • The duty to be claimed for manufacturing substitution will be based on the lesser of the duties paid on the imported merchandise compared to the duties paid on the substituted merchandise if it were imported.
  • The duty to be claimed for unused substitution will be based on the lesser of the duties paid on the imported merchandise compared to the duties paid on the exported article if it were imported
  • Why JM Rodgers? The Best In Duty Drawback

    Many companies that import and export a wide variety of products are not aware of the advantages of the refund of customs duties paid on imported material upon its exportation.

    Most companies that try it themselves wind up frustrated by the amount of paper work, statutory laws, Customs regulations, and procedures involved. Furthermore, drawback is becoming even more confusing as a result of the effects of the various Free Trade Agreements and the constantly changing drawback laws and regulations.

    That’s where J.M. Rodgers Co., Inc., the recognized leader in the field of drawback, comes in. We are serious about providing our clients with the best and most personalized service in the industry.
    Our clients have our “risk free” guarantee:

    • Our clients pay no up front fee.
    • Our clients pay nothing until they receive their U.S. Treasury Department refund check.
    • Our clients pay us a modest percentage of the money that we recover for them.
    • Without any additional charges, this percentage covers:
      • Software or hardware required to handle their account.
      • Our being present at all their drawback audits.
      • Preparing and filing with customs all necessary drawback applications and rulings as well as drawback claims for import refunds.
    • We have purchased a $1,000,000 insurance policy to guard against the unlikely occurrence of errors and omissions in the drawback claims we prepare.
    • We will refund the applicable portion of our fee if any money is returned to Customs due to an error on our part with the drawback claim.

    J.M. Rodgers Company, Inc. has a full staff of highly qualified experts to service your team, with over a quarter of the staff licensed Customs brokers. Using their tremendous expertise and combined experience, JMR’s highly trained support staff of more will get your shipments cleared.

    Exemplary Processing Capabilities

    Our duty drawback processing capabilities are exemplary best-in-class, with honed processes shaped by years of experience:

    1. We use powerful transaction based database software, which is programmed “in house”. This allows us to prepare customized software packages for our clients. We have a complete verification system in place to check the data that goes into drawback claims before they are sent to Customs. We currently have automatic electronic data transfer systems in place as well as various other data medium, all of which are discussed with each client.

    2. We provide Client Summary Management Reports, which vary in format from one client to another.

    3. We file most of our claims in the New York customs region; however, at the request of some of our clients, we do file claims in other drawback Customs regions.

    4. We work towards recovering all the drawback refunds that our clients are eligible to claim.

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