A Global Brand. A Glamorous Image. A Gaping Compliance Risk.
In 2024, a leading global cosmetics manufacturer found itself at a crossroads. Despite the Tokyo-based beauty brand having operations across several continents and a diverse product portfolio, they weren’t getting very far with their duty drawback efforts– a method of recovering tariff-imposed duties, taxes, and fees paid on imported goods that subsequently leave the U.S.
Not only had their previous drawback provider failed to delivery results– primarily due to being unable to secure the required proof of export– the brokerage had been submitting fabricated production dates to U.S. Customs and Border Protection (CBP) arbitrarily set 30 years before export.
An Ugly Truth
“As soon as we started working with this client in February 2024, we were genuinely worried for them,” recalls CITTA Drawback Consultant Sydnee Goodell. “Shortcuts like these weren’t just sloppy, they exposed this beauty brand to a huge compliance risk.”
If audited, Goodell explained, the client would have been required to return all recovered funds to CBP. And they may have completely lost their drawback privileges—a designation they had had since the 1990s.
“When done right, filing for drawback doesn’t increase scrutiny,” Goodell stressed. “But non-compliant filing? That’s not a good look.”
From Fragile To Flawless: Building A Compliant Core
Some customs brokers provide drawback as an ancillary service upon request from clients. By contrast, CITTA focuses solely on recovering duties through building and maintaining drawback programs. Because of this expertise, Goodell and her fellow CITTAzens were able to do more than simply fix past errors. They rebuilt the client’s drawback program from the ground up, ensuring that compliance would no longer be a concern.
“It was a rescue program, for sure,” Goodell recalls. “Neglected, malnourished, and in rough shape. It took a lot of TLC, but we helped it bounce back—stronger and more confident than ever.”
To restore the client’s faith in drawback, their dedicated drawback manager and compliance specialists achieved the following in just 16 months:
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Cleared the Blemishes: CITTA discovered and replaced all previously fabricated production dates with verified, regulation-compliant data, ensuring the company wouldn’t be exposed to compliance risk under the claims CITTA filed on their behalf.
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Reconstructed the Routine: Because the client lacked invoice-level detail from its old system—a challenge Goodell said would make most brokers walk away from such accounts—CITTA manually rebuilt the client’s database, ensuring no eligible refund was left behind.
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Introduced Picture-Perfect Processes: Because the previous drawback provider had failed to secure adequate proofs of export, Goodell says the client was skeptical about whether anyone could help them obtain the necessary documents from their various carriers. But CITTA helped them establish repeatable best practices while verifying and inputting the data necessary for complete, accurate, and compliant claims.
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Layered in Client Confidence: During well-organized weekly progress meetings with the client, CITTA made it a priority to align on documentation, fix production dates and bills of materials, and set up the client’s internal teams for success through education and guidance. Goodell said this went a long way toward ensuring shared ownership and, eventually, a sense of trust she described as a “sea change.”
“Winning someone’s heart through highly compliant drawback claims? Yeah, it’s not the sexiest job in the world,” Goodell admitted. “But just like beauty brands, delivering consistency and reliability are essential to building trust and, eventually, loyalty.”
$1.3M Recovered And Counting
In less than 16 months, CITTA helped this global beauty brand—whose products include skincare, makeup, body care, hair care, and fragrances—recover $1.3 million in duties going as far back as 2019.
Moving forward, Goodell estimates quarterly returns of between $500,000 and $650,000.
Worth A Look?
Whether you’re new to drawback or somewhat experienced—or possibly jaded—we’d love to speak to you.
Visit CITTABrokerage.com.

COMPANY PROFILE
Industry: Cosmetics
Products: Skincare, Makeup, Body Care, Hair Care, Fragrances
Global Headquarters: Tokyo
Importer-of-Record From: China, Japan, Italy, South Korea, Taiwan
Exporter-of-Record To: France, Hong Kong, Australia, Thailand, and Japan