Frequently Asked Questions

Which customs duties and fees can actually be refunded, and which are gone for good?

Ordinary customs duties, merchandise processing fees, and harbor maintenance fees are all refundable at 99% through drawback under 19 CFR 190.3. Antidumping and countervailing duties are not. Most Section 232 metals duties are not either. The recoverable pool depends on which duty layers your entries actually paid, which is why an entry-level review comes before any estimate of savings.

How far back can we recover duty we have already paid?

Five years from the date of import, under the window set by TFTEA. That reaches entries your team likely considers closed. Companies starting a program often find the first filing is the largest one they ever submit, because it covers five years of history rather than a single quarter.

Is reducing duty the same as recovering duty?

No, and treating them as one thing is how savings get missed. Reduction lowers what you pay going forward through classification review, origin planning, and valuation work. Recovery returns duty already paid on goods that left the country or were destroyed. Most importers have room in both. The two run on separate data and separate deadlines.

Who inside the company should own customs duty management?

It works best when finance owns the number and trade compliance owns the accuracy. Supply chain decides sourcing, but only finance sees duty land in cost of goods sold, and only compliance can defend a classification to CBP. Programs stall when duty sits with a single logistics coordinator who has no mandate to change sourcing or pricing.

Can we run a foreign trade zone and a drawback program at the same time?

Yes, though they cover different movements. An FTZ defers or avoids duty on goods that have not yet entered U.S. commerce. Drawback refunds duty already paid on goods that entered and then left. Importers with both inbound staging and export volume usually need both, and the split gets decided entry by entry rather than once at a policy level.

What data do we need before a duty recovery review is worth doing?

Import entry summaries with HTS lines and duty paid, export records with proof of export, and inventory movement that ties the two together by part number. Most of this already exists in an ERP or a broker’s system. The common blocker is not missing data. It is data sitting in three systems that were never designed to reconcile against each other.