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Under Section 301 of the Trade Act of 1974, the USTR initiated an investigation to determine whether China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation are unreasonable, unjustifiable, or discriminatory and burden or restrict U.S. commerce. The resulting action places a 25% punitive duty on approximately $50 billion of imported industrial goods from China.


Duty Refunds Ready to Expire?

2 Billion per year left unclaimed...

Tariff refunds are left unclaimed every year by U.S. companies and corporations. In light of recent trade news, CBP announced that Section 301 duties will be eligible for drawback. Our professionals at Alliance Drawback Services will analyze your program potential and discover the best path forward to maximize your refunds and ensure a compliant filing process.


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.

Why Choose Alliance?

Expedite Your Claims Process

Transfer administrative burden from your company to Alliance's staff of highly trained professionals.

Maximize Your Refund

Not all programs are equal. Here at Alliance, we find your most effective path forward that will ensure the best return without a headache.

Stay Compliant

Our licensed professionals understand the ins and outs of customs regulations. We file claims compliantly under TFTEA.

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 to assessing your company's drawback potential.

The Substitution Provision

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.

Alliance Drawback Services

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.

FREE Consultation

To find out more about how your company can benefit from the duty drawback provision of the Customs Regulations, Click Here or contact us at 239.260.7095 for a no cost/no obligation consultation and assessment of your potential drawback program.


Curious to learn more?

Check out our FREE live webinars with Tony

Our Clients Trust Us

Alliance is a highly qualified drawback service provider with experience in the management of major accounts with large and small firms. Alliance consistently delivers the programs and solutions as promised in the area of duty drawback. Alliance as a quality support staff and they respond quickly to any questions we may have.

Terri DeFronzo

Import/Export Compliance Manager

logitech-logo-clientWe have used Alliance Drawback Services for all of our U.S. drawback needs for a number of years, I cannot think of a better company to provide these valuable services. Thank you, Alliance.

DJ Garner

Director Worldwide Trade Compliance

Gathering the information for the initial applications was made easy with Alliance's professional approach. They knew exactly what information was needed and within a short period of time the application was filed and approved by Customs. I would recommend their services to anyone.

Nelson Cobb

Senior Staff Accountant

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Philadelphia Seminar – Drawback Simplification and Multi-Party Claims Management

September 6 @ 2:00 pm - 5:00 pm
Philadelphia, PA United States
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Miami Seminar – Drawback Simplification and Multi-Party Claims Management

September 20 @ 2:00 pm - 5:00 pm
Miami, FL United States
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Chicago Seminar – Drawback Simplification and Multi-Party Claims Management

October 10 @ 2:00 pm - 5:00 pm
Chicago, IL United States
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Updates From Alliance

Section 301 Tariff Eligibility

By Anthony Nogueras | July 27, 2018

Under Section 301 of the Trade Act of 1974, the US Trade Representative’s Office, under the direction of the Trump Administration, initiated an investigation to determine whether China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation are unreasonable, unjustifiable, or discriminatory and burden or restrict U.S. commerce. The resulting Section 301 action places a 25% punitive duty on approximately $50 billion of imported industrial goods from China. Section 301 Line Items The first list that covers 818 harmonized tariff lines became effective on July 6th, 2018. The second proposed list consists of 284 HTS lines and is currently in the public comment phase. The third list covers over 6,000 tariff lines that, if implemented fully, would place an additional 10% duty on approximately $200 billion on US imports from China. The imposition of the duty will be a significant burden and the first priority is to see if there are not ways to avoid the payment, such as to assign another tariff classification, one that is not subject to the duty, or to source from a country other than China. Are There Solutions? If there is no way to avoid that additional Section 301 duty, then…

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Customs Establishes Wine Drawback Parameters

By Anthony Nogueras | July 8, 2018
bottle of wine and grapes

Customs Headquarters in a long-awaited ruling issued its interpretation related to a provision of the Food, Conservation, and Energy Act of 2008 that addressed the commercial interchangeability of wine for drawback purposes. Section 15421 of the law states—for drawback purposes imported and exported wine will be matched on a color for color basis (e.g. red for red and white for white) within a 50 percent wholesale price variance. The new law, while clear in its general intent, left the door open for Customs to limit its scope through a more restrictive interpretation. The Customs ruling addressed a variety of specific issues raised by the San Francisco Drawback Office in a request for internal advice. San Francisco Customs sought clarification on the following points: 1. Whether wines produced from fermented rice or fruit other than grapes, such as cider, perry, plum wine, prune wine, sake, and mead, are within the scope of section 15421 of the Act; 2. Whether fortified wines that contain in excess of 14 percent alcohol by volume (including fortified dessert wine, sherry, port, and vermouth) are within the scope of section 15421 of the Act; 3. Whether carbonated wines, such as crackling wine, sparkling wine, or effervescent…

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D. Luther: My Customs Broker Handles That

By Anthony Nogueras | July 8, 2018
man in suit checking off todo list

It’s common for importers to rely heavily on the services of their customs brokers. Customs brokers are knowledgeable professionals licensed by U.S. Customs and Border Protection (“CBP”). They are “plugged in” to CBP’s computer systems, and get real-time updates on changes to regulations and practices. Brokers do a complicated job with precision and speed. But there’s a limit to how much importers should rely on them. IMPORTER OF RECORD Under U.S. Customs laws and regulations, the importer of record (the actual owner or purchaser of the imported goods) is responsible for all aspects of compliance, including the correctness of entry information and the payment of duties. See 19 U.S.C. 1484(a)(1). In fact, your customs broker is merely your representative before the agency. It works much the same way as your tax return. Your accountant may prepare the return, but if extra taxes are owed, it’s not your accountant who will be paying them. Under Customs law, the penalty statute (19 U.S.C. 1592) is generally used against importers for false statements, acts, or omissions that affect compliance. (There are separate statutes generally covering brokers’ conduct.) The importer also has specific recordkeeping responsibilities. Importers are required to keep customs records (entries, invoices,…

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