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 President, 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.