The Duty Drawback Blog

On May 28, 2025, a U.S. trade court ruled that President Donald Trump over stepped his authority in imposing the reciprocal tariffs. At that time, the court ordered an immediate block on said tariffs. As of May 29, 2025 a federal appeals court temporarily reinstated the most sweeping of Trump's tariffs. Pausing the lower court’s ruling, The United States Court of Appeals for the Federal Circuit in Washington is going to consider the government's appeal, and has ordered the plaintiffs in the cases to respond by June 5 and the administration by June 9. This is a developing situation and we will do our best to keep the information coming.

This jewelry retailer's duty drawback success story demonstrates the significant impact that a well-managed duty drawback program can have on profitability. By recovering significant funds, the jewelry retailer was able to reinvest in their business, enhance competitiveness, and strengthen their bottom line in a challenging market.

Effective at 12:01 a.m. on April 5, 2025, a 10% baseline tariff on imported goods from most countries, with a few exceptions, will be implemented. This baseline is in addition to regular duties and fees, current IEPPA duties, Section 201 duties, Section 301 duties, and any applicable AD/CVD.

As of 12:01am, March 4, 2025, tariffs of 25% are effective on products from Canada and Mexico and energy products from Canada are subject to a 10% duty. Products that are presently excluded from these tariffs include goods that are for personal use, goods entered under Chapter 98, donations that are imported under HTSUS 9903.01.21and merely information items included under HTSUS 9903.01.22. All other imported items will carry the 25% tariff and no drawback is permitted on these duties.

The upcoming changes to steel and aluminum tariffs will significantly impact the steel and aluminum industries, with numerous provisions to ensure compliance. Importers, exporters, and manufacturers in the steel and aluminum sectors should stay informed about the latest developments and ensure their operations are aligned with these new tariff regulations.

On February 1, 2025, President Trump signed an Executive Order (EO) that imposes an additional 10% ad valorem tariff on most imports from China, which includes products of Hong Kong. U.S. Customs and Border Protection (CBP) quickly followed up with important guidance regarding these changes, particularly impacting the trade community's handling of de minimis shipments from China. Effective February 4, 2025, de minimis shipments from China will no longer be eligible for the administrative exemption from duty under 19 U.S.C. § 1321(a)(2)(C), and will be subject to the new 10% tariffs.  Here's everything you need to know about the changes:

The recent guidance from U.S. Customs and Border Protection (CBP) regarding de minimis shipments from China is a significant update. Here's a quick breakdown of the key points in the alert:

International Tariff Management's February Newsletter

On January 20, 2025, President Donald Trump was sworn in for his second term, and with that came big promises regarding trade policy. But a significant shift came just days later, on January 21, when Trump announced plans to impose 25% tariffs on Mexico and Canada—set to go into effect on February 1, 2025. This move represents a dramatic change in North American trade relations and could have wide-reaching effects on American consumers. At a signing ceremony in the Oval Office, Trump revealed that his administration would roll out tariffs on goods from two of the U.S.'s largest trading partners, Mexico and Canada. However, this new tariff decision doesn’t fully align with the aggressive trade strategy Trump promised during his campaign. The sweeping tariffs Trump pledged on his first day in office, including a 25% tariff on Mexico and Canada, have yet to materialize. His executive action, while still outlining a broad trade policy overhaul, serves more as a placeholder for a more extensive, long-term plan.

Although the United States and Taiwan (officially known as the Republic of China) do not maintain formal diplomatic relations, the two countries share strong cooperation in several areas, including trade. Trade discussions are managed through the American Institute in Taiwan and the Taipei Economic and Cultural Representative Office in the U.S., under an arrangement called the U.S.-Taiwan Initiative on 21st Century Trade. This framework allows both nations to address trade and investment issues, while working toward mutual priorities over time.

As of January 1, 2025, new tariff rates on certain Chinese imports will go into effect, as part of the ongoing Section 301 investigation into China's trade practices, particularly regarding technology transfer, intellectual property, and innovation. The United States Trade Representative (USTR) has announced additional tariff increases under the Section 301 Four Year Review, which impacts a range of products, including certain tungsten products, solar wafers, and polysilicon. If you're involved in importing these products or handling customs filings, it’s crucial to understand the latest developments and the steps required to comply with the updated regulations.

Our team is excited to be back for another year of maximizing refunds and providing exceptional service for our partners!

In his recent article, "Why China Welcomes Trump’s Energy Tariffs", energy and geo-economics expert Wesley Alexander Hill provides an intriguing take on how U.S. tariffs, especially those targeting energy products, might inadvertently benefit China rather than harm it, as intended by former President Donald Trump.

Dr. Naushad Forbes explains the issues surrounding around the WTO and the benefits of utilizing Free Trade Agreements

Free Trade Agreements (FTAs) and U.S. Economic Influence: A Snapshot of 20 Countries Free trade agreements (FTAs) are vital tools for the United States, designed to open international markets to American businesses, enhance the competitiveness of U.S. products abroad, and give consumers access to a broader range of goods in the global marketplace. These agreements also grant the U.S. increased political influence, integrating partner countries into the American economy and making them less likely to align with rivals such as China or Russia. Republican presidents have typically championed FTAs, viewing them as beneficial to business and an essential means of exerting American influence internationally. However, FTAs are controversial. Critics argue that they can lead to the relocation of jobs overseas, as businesses seek to produce goods where labor and materials are cheaper. There are also concerns that FTAs can erode local cultures and lead to cultural homogenization, which is often felt more acutely by smaller, less dominant cultures. These concerns have made FTAs less popular within the Democratic Party.

On December 11, 2024 , the U.S. Trade Representative (USTR) announced increases in tariffs on certain tungsten products, wafers, and polysilicon, following its September 19, 2024, solicitation for comments. These tariff increases will take effect for goods entered on or after January 1, 2025 , and are part of the USTR’s final action under the statutory four-year review of existing Section 301 duties on China.

Happy Holidays! Our team wishes everyone the best in the coming year.

With Donald Trump returning to the presidency, global trade professionals are facing an uncertain and rapidly evolving landscape. Given his past policies and rhetoric, significant shifts in the global trade environment seem likely—shifts that could have far-reaching effects on international markets and economies. In this post, we’ll explore the potential implications of a second Trump presidency on global trade, the key role of trade professionals in adapting to these changes, and crucial areas of focus such as the De Minimis rule, Most-Favored-Nation (MFN) status, export controls, and investment restrictions.

As the possibility of renewed Trump-era tariffs looms, industries are already planning how to protect their supply chains from potential disruptions. President-Elect Donald Trump has proposed imposing blanket tariffs of up to 20% on all imports, and even higher tariffs—ranging from 60% to 100%—on goods from China.

Updates in FTA's and GSP with significant effects of the state of trade for the United States.

For over three decades, the European Union (EU) and the Gulf Cooperation Council (GCC) have been trying to finalize a free trade agreement (FTA). However, despite early talks, the deal has remained elusive. The main roadblock? The EU's tendency to mix economic issues with political and ideological concerns—an approach that has ultimately hindered progress.

The US-Morocco Free Trade Agreement (MAFTA), signed in 2004 under President George W. Bush, was a landmark deal aimed at strengthening economic and strategic ties between the U.S. and Morocco.

In a significant development for U.S.-Chile trade relations, the two nations have approved a pivotal agreement that bolsters the existing Free Trade Agreement (FTA) between them. This new accord, formalized through an exchange of letters, introduces enhanced protections for U.S. cheese exports to Chile—an essential market for American dairy products.

The lapse of the GSP has not only disrupted these economic plans but has also intensified the geopolitical landscape. As the U.S. grapples with domestic political divisions and a rethinking of its trade policies, China has stepped into the breach.

U.S. Customs and Border Protection (CBP) has recently issued a crucial reminder to businesses regarding the compliance requirements for drawback claims. As many companies navigate the complexities of customs regulations, it’s essential to understand the consequences of failing to meet these requirements.

The U.S. Trade Representative's Office released their four-year review of the Section 301 Tariffs which call for retaining the duties currently in place along with an increase on entire classes of Chinese imports.

CBP made an update to the Automated Commercial Environment or ACE Portal which will be useful to brokers and filers. Import refunds are now visible through the Broker’s ACE Portal Account. Using the REV - 603 report, you can now search for refunds by utilizing refund date search parameters.

In the intricate world of international trade, various mechanisms exist to facilitate smoother transactions and encourage commerce across borders. One such mechanism is duty drawback, a process that offers significant benefits to businesses engaged in importing and exporting goods. In this guide, we will delve into the concept of duty drawback, its benefits, and how businesses can leverage it to their advantage.

The implications in the case of Union of India and ORS. v. Patil and Sons Belgaum

Department of Commerce's new policies and trade community advancements

Recent news from CBP regarding cargo messaging and expediting cargo shipping

We are excited to announce our first monthly newsletter! Our goal of this new endeavor is to keep our clients and the companies in our network up to date with all information regarding drawback, CBP and more!

A free trade agreement (FTA) is an agreement between two or more countries where the countries agree on certain obligations that affect trade in goods. Currently, there are 14 Free Trade Agreements in effect in the U.S. with 20 different countries. An importer collects and maintains the information to support the FTA qualification. An exporter from the U.S. is required to complete a declaration verifying that their goods qualify for free trade with the participating country. The rules associate with FTAs are complicated and the analysis is intricate. There are multiple steps to the process and each one must be completed in order to move onto the next. 1. Classify the product according to the HTSUS in order to determine the rule of origin for the specific finished product 2. Choose a preference criteria from the 4 available. 3. Use the rule of origin to determine the qualification of the finished good.

How proper classification can equate to big savings for your company.

Duty Drawback is a refund from Customs, for 99% of the duties paid on imported materials that are subsequently exported, destroyed or used in the manufacture of exported goods. Today, only about 25 percent of eligible duty is being recovered. This means that $5 billion dollars goes unclaimed for drawback, and that money might be yours. So, how do you know if you are a candidate for a lucrative duty drawback program?

The new drawback regulations are written and will take effect on February 24, 2019. That’s less than a month from now!! ITM is prepared to continue filing on behalf of all of our clients and we are excited about the possibility of new opportunities that will now exist under the new guidelines.

Customs has maintained that the ultimate goal of TFTEA is to streamline and simplifying the drawback process. At this time, there are no formal regulations in effect, but the guidelines have been released and reviewed extensively by the trade. After much conversation and deliberation, the trade was allowed and has formally submitted a response to Customs on these proposed regulations and now waits the allotted 90 days to find out how they have been received and what the final determinations will be.

In April of 2018, the current administration announced that it would impose increased tariffs on items imported from China. By April of 2018, the Office of the US Trade Representative (USTR), released the first list of 1,300 tariff numbers subject to an additional 25% duty. That list, referred to as US List 1, went into effect on July 6th and included steel and aluminum. The USTR announced that this would subsequently be followed by a List 2 and 3.

Why it's important to prepare for TFTEA drawback under the new and more flexible standards.

Did you hear that Customs is simplifying the duty drawback regulations? Have you avoided starting a program because it’s too complicated, too frustrating or just too much work?

Join us on June 8th @ 2:00 pm (ET) for our new 20-minute webinar: Free Trade Agreements. In this informative webinar, we will show you how to take full advantage of Free Trade Agreements.

Utilizing the benefits associated with Free Trade Agreements (FTA’s), is one of the best ways for U.S. exporters to sell their goods and services in foreign markets. Because there are fewer trade barriers, FTA’s enable U.S. companies to compete internationally. According to the International Trade Administration, 47% of U.S. goods that were exported in 2015 went to FTA partner countries. Those exports totaled $710 billion dollars. Many companies do not take advantage of the savings afforded them by participating in trade with FTA countries because they (1) are not aware of them, (2) do not understand them, or (3) do not have the resources to implement them.

Learn the three key factors to determine if you are paying too much Duty on your imports.

The first thing you need to do is evaluate the connection between your imports and your exports. On a macro scale, you will need to determine the amount of duty you pay per year on imports (e.g. $250,000). Next, identify what percentage of your total sales is exported (e.g. 10%). Now multiply the percentage of exports times the amount of duty paid per year on imports, you will get a ball park estimate of your duty drawback recovery potential ($25,000 per year in this example). Of course every import is not exported, but this is a good calculation to use in order to establish a general starting point. The duty drawback regulations allow a claimant to go back 3 years when claiming drawback on exports, so using the example above this company would get an initial potential recovery of $75,000. If after using the calculation method above, you find that pursuing a duty drawback program seems viable, the next aspect for consideration is the clarification of the exporter of record. By law, the exporter of record is the party entitled to claim duty drawback. If you are not the exporter of record, those rights can be transferred back to you by the exporter of record, but this is an additional step that warrants consideration. The third point to assess is your company’s import history and available supporting documentation. You need not be the direct importer in order to claim duty drawback. If you obtain imported merchandise from a domestic third party, you can use that material in a duty drawback program by obtaining certificates of delivery. Again, this is an additional step in the process, one in which can be simplified by acquiring the services of a duty drawback professional. Once you have determined that you have a viable duty drawback program, a potential claimant will need to obtain permission from U.S. Customs and Border Protection in order to file the duty drawback claims. These permission letters include accelerated payment, waiver of prior notice, and in the case of a manufacturing process, a specific or general drawback ruling. When the applications have been filed with Customs, the duty drawback claims can then be submitted. It is imperative that a claimant files the older exports first, most importantly because you will begin to lose the ability to claim them once you exceed the statutory 3-year period. Once your applications are approved, payment should be received from Customs in approximately 30 days.

Join us on August 30th @ 2:00 pm (ET) for our new 20-minute webinar: DUTY DRAWBACK 101. In this informative webinar, we will introduce you to the concept of Drawback and how to use it to get money back from the U.S. government.

To explain duty drawback simply, if you import something into the US, pay a duty or tax on it and export it as is, or as part of a US manufactured product, you can recoup 99% of the duty paid on the import upon the export.

Importers and exporters trading with foreign countries may be eligible for free trade agreement benefits. Contact us today for a review of your circumstances to see if you can save money while ensuring compliancy.

To explain duty drawback simply, if you import something into the US, pay a duty or tax on it and export it as is, or as part of a US manufactured product, you can recoup 99% of the duty paid on the import upon the export.

ITM has collected hundreds of thousands of dollars for PEM America, none of which we would have recovered without their help. If you're not going to use this service, you'll be leaving an awful lot of money on the table.