ICBC Conference Attendees:
International Citrus & Beverage Conference, organized by the University of Florida will take place from 18th September to the 21st September 2018 at the Sheraton Sand Key Resort in Florida, United States Of America. Please click the button below to download the PDF version of the presentation with an area for personal note-taking on each slide.
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.
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.
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.
Import/Export Compliance Manager
We 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.
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.
Senior Staff Accountant
Updates From Alliance
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…Read More
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:…Read More
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 enacted as “The Trade Facilitation and Trade Enforcement Act of 2015.” The legislation set in motion an extensive and fundamental transformation of the 200-plus-year-old duty minimization strategy known as duty drawback refunds. Simply stated, the drawback program allows for the refund of duties on imported merchandise that is subsequently exported from the United States either in the same condition or following a manufacturing process. The new drawback statute mandated a two-year implementation process to allow Customs and Border Protection ample time to draft and implement a new regulatory regime as well as complete the full automation of drawback claim submission through its electronic platform referred to as ACE (Automated Commercial Environment). Currently a small portion of each drawback claim is submitted electronically via automated broker interface (ABI) so that Customs can perform a series of validations within Customs Automated Commercial System (ACS). Surprising to some in the Trade Community, Customs supported the liberalization of the substitution provision of the drawback law. Under the existing drawback regime, imports and exports are essentially matched at the…Read More