Alliance Drawback Services, Inc.

Duty Drawback

Who Are We? Founded in 2001, Alliance Drawback Services, a drawback specialty firm, provides drawback services related to the implementation, administration, and management of duty drawback recovery programs. Alliance provides a turnkey drawback solution that transfers the administrative burden of the drawback process from your company to Alliance's staff of professionals. We assist the trade community in collecting tens of millions in drawback recoveries each year. Prominent drawback clients include Sunsweet Growers, Logitech and Control 4 Corporation to name a few.

What is Duty Drawback? First passed by the U.S. Congress in 1789, the duty drawback law found in 19 USC 1313 allows importers receive refunds on import duties on merchandise that is subsequently exported. Refunds of import duty through the drawback refund program increases U.S. export activity by making our exports more price-competitive.

Imported merchandise can be exported in either the same condition (referred to as Unused Merchandise Drawback) or following a manufacturing process (known as manufacturing drawback). Understanding the concept of "substitution" is key assessing your company's drawback potential. The substitution provision of the law applies to both Manufacturing as well as Unused Merchandise drawback allows a drawback claimant to match exports and imports of like, but not identical, merchandise. The regulatory requirements found in 19 CFR Part 191 requires the matching of only "commercially interchangeable". Think of imported apples for exported apples but of the same variety and grade. Note that the new drawback law found in HR 644 expanded the substitution concept dramatically liberalizing the rules so that any import and export that fall into the same 8 digit harmonized tariff schedule number are considered interchangeable for drawback purposes. Now think apples for apples but without regard for grade or variety.

With corporate headquarters located in Southwest Florida and affiliate offices in Los Angeles and Miami, Alliance maintains a staff well-trained in the management and administration of duty drawback recovery programs. Our specialized drawback programs, processes and personnel allow drawback claimants to maximize duty recovery while maintaining the highest degree of compliance with the drawback regulations found in 19 CFR Part 191. To find out more about how your company can benefit from the duty drawback provision of the Customs Regulations, contact us at 239.260.7095 for a no cost/no obligation consultation and assessment of your potential drawback program.

Drawback Eligibility

Duty Drawback Refund Experts

As a drawback specialist, we offer claimants a turnkey drawback solution that allows them to participate in the program with a minimal commitment of personnel resources. We customize our approach to meet the unique requirements of each of our drawback clients.

Our Duty Drawback Services
North American Free Trade Agreement (NAFTA)

The Duty Drawback Process

We take full responsibility for the drawback process from the initial implementation of the program to the filing of drawback claims. Our success is based on our excellent relationship with Customs and Border Protection (CBP) personnel and knowledge of the laws.

Custom Duty Drawback Programs
Drawback Claims

Regulatory Compliance

During the implementation visit we will review the types of records routinely required to substantiate claims during a Customs audit. While only a small portion of claimants will actually be audited, we prepare for the possibility of an audit from the inception of the program.

Duty Drawback Claims
Duty Drawback FAQs


Is duty required on U.S. made goods returning to the U.S.? U.S. made goods returning to the United States are usually eligible for duty-free treatment. The Harmonized Tariff Schedule (HTS) allows U.S. made products to return to the U.S. without duty requirements.

What is Duty Drawback?

Article by Tony Nogueras January 10, 2018

New Drawback Law

Drawback Definition

Article by Anthony Nogueras, Founder and CEO of Alliance Drawback Services, "TFTEA Drawback Update: Customs May Suspend Accelerated Payment of Drawback Claims Filed Under TFTEA". Unfortunately for the drawback trade community, the transition from the existing drawback program to the new regime required by the passage of The Trade Facilitation and Enforcement Act of 2016 threatens to disrupt payment of drawback claims starting February 24th of this year, the new law’s official effective date. The passage of new statute requires changes to the more detailed regulatory structure as well as adjustment of internal administrative procedures. Given the deadline date of February 24, 2018, the trade community expected the proposed rule-making to be formally published in the Federal Register long before now to allow ample time for public comment and dialogue between the trade community and Customs prior to finalization of the rule making. Unfortunately, CBP has indicated that payment of drawback claims under the “accelerated” program maybe be suspended if the new regulatory structure is not finalized by the new law’s effective date…now a forgone conclusion. Read the entire Article

New Workshop July 11, 2017 in Woodbridge, NJ

The Complexities Of Drawback Simplification!

• Overview of the Existing Drawback Law
• Understanding the New Drawback Law: The problem of "Other" Classifications
• Manufacturing Drawback
• Unused Merchandise Drawback
• NAFTA Drawback Restrictions: Changes coming with NAFTA Renegotiations?
• Processing of Drawback Claims: New Procedures, New Challenges
• Compliance, Reviews, Penalties • Transition of Drawback from ACS to ACE

July 11, 2017. Pricing $350 per attendee! Location: Woodbridge, NJ.
Register here for this Workshop!

AAEI advocates on behalf of U.S. companies on trade policy issues before the U.S. Congress, trade compliance practices and operations before Executive Agencies, and multi-lateral organizations including the World Trade Organization and the World Customs Organization. AAEI plays an important role in providing education to international trade compliance professionals through its ten (10) standing committees which review proposed trade policy and regulations for comment, off-the-record webinars with government officials, and the Association’s annual conference, seminars and trade briefings.

More about AAEI

NACD was established to enhance and communicate the professionalism and stewardship of the chemical distribution industry. NACD Vision is to be the premier authority for chemical distribution in the United States, to strive for excellence in its Responsible Distribution Program, to advocate sound government policies, and to promote the continuous improvement of member companies. NACD's nearly 450 member and affiliate companies represent more than 85% of the chemical distribution capacity in the nation and 90% of the industry's gross revenue. They are typically small businesses, although some companies are national or international in scope. They know their products and processes and provide value-added services to their customers in a professional, responsible manner.

More about NACD

The Florida Customs Brokers & Forwarders Association, Inc. was founded in 1960 by a handful of Miami brokers and forwarders. FCBF has since grown into the most influential and active representative body of the Florida freight forwarding and customs brokerage community. Through its numerous committees of volunteer professionals, the FCBF represents our industry on matters that directly affect the trade arena. It has been the commitment of FCBF to foster communications between the trade community and the federal agencies in order to expand Florida’s trading communities at the local, state, and national level. FCBF seeks to maximize the ability of the State of Florida to effectively compete for international trade resources and to minimize the barriers for its members. Through constant communication with various state and federal agencies we help by participating in the development of international trade policies.

More about FCBF

Duty Drawback

News Archive

New Drawback Law

Posted In: News, Archive

"Understanding The New Drawback Law: The 'Other' Problem"

The primary liberalization of the duty drawback law passed as part of the Trade Facilitation and Enforcement Act of 2015 (TFTEA) involved redefining the substitution provision of the drawback law. While this “game-changer” will increase drawback recovery dramatically, the devil, as the saying goes... More

New Drawback Law

Posted In: News, Archive

"Customs Transition of Drawback to ACE Under New Regime Delayed"

A 12-year collaborative effort between Customs and Border Protection and the Trade Community resulted in a new drawback statute found in Section 903 of HR 644. The legislation set in motion an extensive and fundamental transformation of the 200-plus-year-old duty minimization strategy known as... More