New Duty Drawback Regime Greatly Benefits Titanium Industry

TFTEA Titanium HTS Substitution

The Trade Facilitation and Enforcement Act of 2016 (known by its acronym TFTEA) profoundly altered the tariff mitigation strategy commonly referred to as duty drawback refunds. The amendment of the Tariff Act represented the culmination of a nearly 12-year collaboration between the Trade Community and Customs and Border Protection in an effort to simplify the […]

TFTEA Transition Update: Joint Customs and Drawback Trade Community Working Group

TFTEA Transition Update

Members of the AAEI and NCBFAA (trade compliance organizations) Drawback Committees, Alliance included, met with CBP Drawback Officials in Virginia in late August to review outstanding issues with TFTEA drawback and ACE drawback filings. The CBP contingent consisted of national-level Customs officials from the Office of Trade Commercial Operations as well as attorneys from Regulations […]

Understanding Multiple Party Drawback

Multiple Party Drawback

The drawback regulations (found in 19 CFR 190) allow for the transfer of drawback rights when the importer and exporter of record are not the same entity. While either entity can submit the drawback claim to Customs (referred to as the drawback claimant), the drawback regulations grant the exporter the first right to submit the […]

Section 301 Tariff Eligibility

301 China Tariff

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 […]

Understanding The New Drawback Law: The “Other” Problem

New Drawback Law - Other

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, is in the details. Some background: The substitution method allows a […]

D. Luther: My Customs Broker Handles That

Customs Broker

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 […]

Customs Establishes Wine Drawback Parameters

Wine Duty Drawback

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 […]

TFTEA Drawback Update: The Day of Reckoning is Upon Us!

TFTEA Drawback Update

This week we enter the transition period from historical drawback regime to the new era promulgated by the TFTEA (Trade Facilitation and Enforcement Act of 2015 also referred to as the New Drawback Law) which officially becomes operational Saturday, 2/24/18. Alliance staff will begin submitting claims via the new drawback module in ACE on this […]