With the official release of the Modernized Drawback NPRM on August 2nd, the time period during which CBP and the Treasury Department are accepting comments concludes on September 17. We have been hard at work to maximize these 45 days to ensure we have covered all topics that are relevant to our clients and voice concerns on language that may negatively impact their drawback refunds. Our focus so far has been on the following topics:
  • Acquisition value as required for TFTEA Manufacturing drawback
  • Retail returns
  • Transfer of merchandise for third party drawback requirements
  • Application requirements
  • Language changes that make drawback opportunities more restrictive
If your company is willing to support our arguments, please contact Margo VanHeusden (mlvanheusden@dutydrawback.com) and you will be provided with the comments in advance of September 17th so that you can submit them directly.