Whereas duty drawback remains an attractive option for companies to recover duties paid on imported goods that are subsequently exported, the drawback provisions found in the Trade Facilitation & Trade Enforcement Act of 2015 (TFTEA) raised the bar on how filers can qualify for a duty refund. With updates published in “Modernized Drawback” (19 CFR Parts 181, 190 & 191), filers of all types know that the level of detail they must now provide in support of a drawback claim is considerably greater. 

Filers have also discovered that TFTEA has not made their job, the preparation of data needed by their drawback broker, any easier. The validation of data across multiple sources, from ERP to ACE to Broker data has become more complex, even for the simplest of entries. Add in the additional requirement for inventory lots (J1) or Bills of Material (Manufacturing), the difficulties related to data compound, creating a level of complexity that most organizations are not capable of overcoming.

In recognition of the above, 3rdwave is conducting a 3-part Webinar Series entitled, “Duty Drawback in the TFTEA Era: Three Solutions to Three Very Specific Challenges”. During each webinar, we will focus on one especially demanding data challenge associated with a specific type of drawback entry and then explain how 3rdwave’s drawback software solution helps to alleviate the burden of manually mining, aligning and refining data requirements.

Part 2: Unused Merchandise Substitution Drawback and the “Other, Other” Problem

Companies that are engaged in Unused Merchandise Substitution Drawback should be familiar with the “Other, Other” problem, where the 8-digit HTS number begins with “other” AND the 10-digit HTS number also begins with “other”. Products that are “other, other” are not eligible for this kind of drawback. But that does not mean that drawback is not possible for these products. It simply means that a different provision must be used, typically one that is more data intensive.

In Part 2 of the series, we’ll be discussing how to achieve the maximum drawback claim, and how not to be overwhelmed with the new data challenges that will be presented as a result of needing to file under a more rigorous provision.

Register for Part 1: Manufacturing Substitution Drawback and Bills of Material

Register for Part 3: Maximizing Your Drawback Claim While Building a Better Relationship with Your Drawback Broker