Prevent Section 301 Profit Slashing

10% or 25%? 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.


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.

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?

Duty Drawback Law

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 duty 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.

Duty Drawback 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.

Schedule Free Analysis

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

Updates From Alliance

Section 301 Tariff Eligibility

By Anthony Nogueras | July 27, 2018

RECENTLY UPDATED! Public Comment Period Officially Ends for List 3 of Section 301 Duties The time-frame for implementation of List 3 is uncertain, but most likely will occur in the coming weeks once the Office of the USTR has considered the public comments. If List 2 serves as any indication, the chances of removing a classification from the list are slim as only 5 of 284 tariff classifications were excluded from the initial list following consideration of comments related to List 2. According to supporters of the tariff measures, including various trade associations representing the textile industry, much of the policy justification for the assessment of these punitive tariffs centers on China’s elaborate system of obtaining America’s valuable intellectual property, innovations, and the theft of specific technology. In the case of all tariffs imposed pursuant to the Section 301 proceedings, USTR provides US importers with another opportunity to seek exception from the Section 301 tariff via a product based exclusion process. Once again, if the procedures for list 2 are any indication, interested parties will have 90 days from the date of implementation of List 3 to formally apply for a product exclusion. Skip to Our Drawback Solutions Why Are…

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Understanding The New Drawback Law: The ‘Other’ Problem

By Anthony Nogueras | July 8, 2018

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 drawback claimant to match “commercially interchangeable” or like merchandise within broad time parameters instead of directly tracing an export back to its exact import. The current law and regulatory structure primarily relies upon the part number and quality specifications to determine if an import and export meet the standard of commercial interchangeability. For example, an export Grade A Orange Juice made from domestic oranges could be substituted or matched with imported Brazilian duty-paid Grade A Orange Juice because they both meet the same basic quality standards and industry specifications. In the case of merchandise identified by a part number or model number (electronics and retail merchandise, for example), generally the imported item and exported item must share the same part-number identifier to be considered substitutable for drawback purposes. As an example, a company imports sunglasses from China into its U.S. distribution facility. The majority of…

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

By Anthony Nogueras | July 5, 2018

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 date. We are hoping for the best, but the more cynical among us fears a complete initial failure of the ACE drawback module once live filing commences on Saturday. The latest on the challenging transition: Interim Rule Making – In the absence of regulations finalized in time for the new law’s implementation date on 2/24/18, CBP decided to issue temporary interim rulemaking for drawback filers and brokers. We have provided you a copy of the Interim Guide on your right. The impact on all these monumental changes will vary for each filer based on the applicable legal provision. Alliances’s team can assess a claimant’s program and develop a filing strategy that compliantly maximizes recovery. The following summarizes the various options available under TFTEA as well as the existing drawback law (also referred to as “Core” drawback in the Interim Guide on your right): TFTEA Filers:…

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