We Take The Term “Drawback Specialist” Seriously.

This is evidenced by our focus on ensuring the majority of our staff members are licensed Customs brokers, are kept appraised on the latest industry news, and contribute to political and regulatory changes. Our company was instrumental in the formation of the current duty drawback regulations for the U.S. and continues to play an active role in ongoing revisions to policy and interpretation of the Statute and regulations.

The following are highlights of the active role our company has played in the course of history of the duty drawback program:

We were actively involved with the negotiations for the Drawback Modernization legislation that passes as part of the Trade Facilitation and Trade Enforcement Act (TFTEA) of 2015, which was signed into law February 24, 2016 by President Barack Obama.

Once the regulation text was released, several members of our staff were proactive in the extensive review for 19 C.F.R §190 and were successful in recommending new language for the regulations in several key areas including values for manufacturing drawback and for proof of export.

We were the only duty drawback specialists to appear in person before the Trade Subcommittee of the U.S. House of Representatives Ways and Means Committee. Comstock and Holt’s Chief Executive Officer, David N. Simcox, testified before this group to encourage their support for the duty drawback provisions of the Customs Modernization Act.

Holt submitted written testimony to the Senate Committee on Finance concerning the Customs Modernization portion of the Trade Expansion Act.

Most of the wording changes in the drawback portion of the Customs Modernization Act of 1993 were either written by us exclusively or in collaboration with U.S. Customs and Border Protection 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 introduced the concept of “unused merchandise” to replace that of “same condition merchandise” in 1992. The new concept was subsequently added to the Customs Modernization Act.

Representatives from Comstock 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.

We work with the U.S. Trade Representative’s office for inclusion of drawback rights in Free Trade Agreements (FTA) and in dialogue for potential changes in existing FTAs.

“Our firm has successfully leveraged the services of Comstock & Theakston over several decades. Our continuance reflects our recognition of results. We have always stressed together the key underlying components of compliance in sustaining a viable Duty Drawback program for the long run. We have leveraged Comstock’s education and training opportunities, both in our facilities and at their site, to assure Duty Drawback program knowledge and compliance expectations from both the CBP and company prospective are conveyed and applied. We look forward to continuing this highly valued partnership.”

—Multinational chemical manufacturer

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