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The Duty Drawback Specialists

Comstock & Theakston, Inc. (Comstock) is unique among drawback specialists because of our leadership during the lengthy process of updating the duty drawback law as part of the Customs Modernization Act. We introduced the concept of "unused merchandise" to replace that of “same condition merchandise” to U.S. Customs in 1992. The new concept was subsequently added to the Customs Modernization Act. Most of the wording changes in the drawback portion of the Customs Modernization Act were either written by us exclusively or in collaboration with U.S. Customs and a few other participants. The drawback portion of the Customs Modernization Act was subsequently brought before the U.S. House of Representatives through our direct initiative.

We are also very well respected by U.S. Customs for being professional, conscientious and cooperative on both the national level in Washington, DC and the port level in New York/Newark. Our relationship with U.S. Customs on the national level has become increasingly interactive in recent years.

In addition to our excellent working relationship with the legal team at U.S. Customs Headquarters, we are also politically active, as foilows:

• We were the only duty drawback specialists to appear in person before the Trade Subcommittee of the House Ways and Means Committee, U.S. House of Representatives. Comstock’s President, David N. Simcox, testified before this group to encourage their support for the duty drawback provisions of the Customs Modernization Act.
• C.J. Holt’s President, Edwin W. Van Ek, submitted written testimony to the Senate Committee on Finance concerning the Customs Modernization portion of the Trade Expansion Act.
• Much of the language in the duty drawback section of the Act was written by William A. Hagedorn who served on a committee charged with the task of drafting this bill.
• Both William A. Hagedorn and Edwin W. Van Ek met with former Customs Commissioner George Weise when he was staff director of the House Ways and Means Subcommittee on Trade. They negotiated details of the drawback portion of the Customs Modernization legislation.
• We introduced drawback legislation in the Miscellaneous Trade Act of 2004 and are currently playing an integral role in the introduction of several new bills concerning drawback and the assessment of the position of drawback in all Free Trade Agreements.

On the port level, we file all of our claims with Customs in New York/Newark. We have an excellent relationship with their drawback specialists and Supervisory Drawback Specialists. We also work closely with the Drawback Branch Chief who is located in the New York/Newark Region and acts as Customs National Drawback Coordinator. She has met with us in our Oradell, NJ office several times to approve claiming procedures and/or to discuss duty drawback policy.