Workflow — Duty Drawback Claim Preparation

TFTEA drawback claims at one-third the contingency.

Import entries, export documentation, manufacturing records, and inventory turns → import-export matching per substitution or unused-merchandise rules, duty refund calculated, claim package built. TFTEA drawback claim filed via CBP ACE for the licensed broker review. Replaces 15–25% contingency at Charter Brokerage, Sandler Travis, Comstock at a fraction of the cost.

Take the AI Assessment Get a Per-Claim ROI Model

15–25%

Contingency at drawback specialists

99%

Of duties paid eligible for refund under TFTEA

60–85%

Routine prep off the specialist line after AI cutover

What This Replaces

The Drawback Specialist Taking 15–25% of Every Recovery

The work the drawback specialist does on every claim — and the cost of leaving it on contingency.

The labor

Duty drawback claim preparation today moves through specialist firms — Charter Brokerage, Sandler Travis, Comstock — pricing structures around contingency at typically 15–25% of duties recovered. Many importers leave drawback recovery on the table entirely because the specialist economics don't cover their volume, or because the import-export matching work for substitution or unused-merchandise drawback is operationally too intensive for the in-house trade-compliance team.

The cycle time

Standard drawback cycle runs months from claim prep through CBP review and refund issuance, with longer cycles on substitution drawback and on claims requiring manufacturing records. The 5-year statute of limitations from import date creates ongoing claim-aging pressure — duties paid more than 5 years ago are gone forever. Specialist contingency models structurally underutilize the population of duties eligible for refund.

The Workflow

Input · Analysis · Output

What goes into drawback claim prep, what we do to it, and what shows up in CBP ACE.

Input

Import entries + export documentation

Import entries (Entry Summary 7501)
Duties paid records
Export documentation (BOL, AWB, EEI / AES)
Manufacturing records and BOM
Inventory turns and FIFO / LIFO lot tracking
Prior drawback claims and CBP rulings
Customer / supplier-of-record context

Analysis

Match, calculate, qualify

Import-export matching per substitution rules (TFTEA 8-digit HTS)
Unused-merchandise drawback qualification
Manufacturing drawback (rejected merchandise, etc.) qualification
Duty refund calculation per TFTEA
Statute-of-limitations check (5 years from import)
Privileged / non-privileged status determination
Confidence score per match; exceptions to drawback specialist queue

Output

Drawback claim into CBP ACE

TFTEA drawback claim package
Import-export match documentation
CBP ACE drawback filing draft
Refund-tracking workflow
Per-claim audit trail with match basis
Recovery dashboard for treasury
Substitution / unused-merchandise / manufacturing claim categorization

Side by Side

Duty Drawback Today vs. With Last Rev

The numbers that matter: cost structure, claim coverage, recovery rate, and CBP-defensibility.

Dimension	Contingency Drawback Specialist	Last Rev Duty Drawback
Pricing model	15–25% contingency on duty recovery	Volume-tiered, benchmarked at one-third the specialist contingency rate
Claim population coverage	Bounded by specialist economics — large claims only	Full eligible-population review at AI cost
Cycle time, claim prep through filing	Weeks-to-months at the specialist	Days per claim batch
Substitution drawback consistency	TFTEA 8-digit HTS matching is operationally intensive	Per-import-entry match cited per claim line
Manufacturing drawback handling	Manual BOM and inventory-turn analysis	BOM and inventory data reconciled per drawback rule
CBP ACE integration	Manual filing through specialist software	Direct via ABI / ACE feed for broker review
Audit log per match	Specialist notes, no per-line lineage	Source import + export + manufacturing records + match basis per claim

How It Works

From Import-Export Population to ACE-Filed Claim

Five steps. Every one logged. Every one reversible if your confidence threshold isn't met.

Submission Lands

Import entries with duties-paid records, export documentation (BOL, AWB, EEI / AES), manufacturing records and BOM, inventory turns, and prior drawback claims pulled into the same review.

Extraction & Classification

Import-export matching per TFTEA 8-digit HTS substitution rules. Unused-merchandise and manufacturing drawback qualification. Duty refund calculation. Statute-of-limitations check (5 years from import). Privileged / non-privileged status determination.

Validation Against TFTEA Bar

Findings validated against TFTEA drawback rules and the importer's drawback playbook. Anything below your confidence threshold per match is routed to the drawback specialist review queue — final filing remains with the licensed broker.

Push to CBP ACE

TFTEA drawback claim package assembled. CBP ACE drawback filing draft for broker review. Refund-tracking workflow initiated. Substitution / unused-merchandise / manufacturing claim categorization recorded.

Audit Log Persisted

Every import-export match, drawback-rule application, and refund calculation logged with the source documentation, model version, and confidence score. CBP-drawback-audit-ready and yours.

Compliance & Defensibility

Built to Meet the Quality Bar Drawback Operations Already Run On

TFTEA / 19 USC 1313 conformance

Trade Facilitation and Trade Enforcement Act (TFTEA) drawback rules under 19 USC 1313 — substitution drawback, unused-merchandise drawback, manufacturing drawback — tracked and applied per claim. CBP regulation updates flow into the validation engine within days of effective dates.

Statute-of-limitations defensibility

5-year statute-of-limitations from import date tracked per entry so claims never lapse silently. Aging-import alerts surface for proactive claim filing on pre-expiration entries.

CBP drawback-audit defensibility

When CBP audits a drawback claim post-payment, the audit log produces what was matched, which TFTEA rule applied, and what the basis was. Cleaner chain of custody than the specialist reconstruction post-audit, and CBP review-time goes down materially when the claim file is structured.

Importer / exporter confidentiality

Drawback claim data contains importer pricing, supplier identity, and competitive trade-flow information. Deployable in your VPC or our SOC 2 environment. Encryption in transit and at rest; retention policies tied to CBP recordkeeping rules.

Common Questions

What Importers and Exporters Ask About Duty Drawback

Those are the drawback specialist firms that prep and file claims today on contingency at typically 15–25% of duty recovery. The competitor on this page is the specialist labor itself plus the contingency margin. We integrate directly into your existing customs platform, prep claims on the full eligible-population at AI cost, and deliver TFTEA drawback claim packages for broker review and ACE filing — without the contingency margin.

Most importers keep the specialist arrangement in place during pilot and early production — we route exceptions, complex multi-program drawback, and any claim that genuinely requires specialist judgment to the team you already have. Volume to the specialist drops 60–85% on routine prep once cutover completes. You renegotiate at the next renewal from a much better position, often shifting the relationship to higher-complexity work like accelerated drawback program design or specialty drawback (e.g., destruction).

Our pilot success threshold is import-export-match and refund-calculation accuracy at parity with or above your incumbent specialist, measured on the same shadow-data sample of historical claims. Anything below your defined confidence threshold per match is routed to the specialist review queue — your call which queue, ours or yours.

TFTEA 8-digit HTS substitution drawback rules are encoded so per-line matches across import and export documentation respect the substitution criteria. The audit log records the per-line match basis cited so post-claim CBP audits resolve cleanly. Specialist contingency models structurally underutilize substitution drawback because the per-line analysis is operationally too intensive — at AI cost, full substitution coverage becomes feasible.

Manufacturing drawback claims (rejected merchandise, processed merchandise, etc.) draw on BOM, inventory-turn data, and manufacturing records. We integrate with your ERP and shop-floor systems to extract the production records that support the manufacturing-drawback claim. We don't make the senior drawback judgment call on borderline programs; we surface the basis so the specialist makes the determination on a richer file.

Yes — through the documented integration surface each platform supports. CBP ACE via the ABI / ACE drawback module; SAP GTS via SAP integration patterns; Oracle GTM via APIs; Descartes via REST APIs. Your IT and trade-compliance teams review and approve service accounts. We do not require platform-side custom development.

Drawback pilots typically run 6–8 weeks: 1–2 weeks of integration and per-program drawback-rule mapping with the trade-compliance team, 4 weeks of shadow-mode running on real import-export populations with no ACE-side claim filings, 1–2 weeks of supervised cutover on a constrained scope (one drawback type, one trade lane). Production rollout is staged after the pilot meets your accuracy and broker sign-off.

We benchmark against your current specialist contingency rate (15–25% of duty recovery) restructured around volume tiers and outcome SLAs. Our target is one-third the specialist contingency rate fully loaded, while reviewing the full eligible population. Recovery typically goes up materially because claims that the specialist economics ignored come into scope.

Two Ways to Start

Take the AI assessment for a structured read on duty-drawback feasibility. Or talk to us if you already know your specialist contingency is the line item you want off your trade-compliance budget.

Self-serve · 8 minutes

Take the AI Assessment

A short structured assessment that maps your annual import / export volume, customs platform, and current drawback specialist arrangement to AI feasibility and ROI.

Talk to a specialist

Get a Per-Claim ROI Model

Send us your annual import / export volume, your customs platform, and your current drawback specialist arrangement. We'll come back with a per-claim unit-cost comparison and a 6–8 week pilot plan in 5 business days.

Other Workflows

More Logistics & Trade Workflows We Replace

The same approach, applied to the other document-heavy labor lines on your trade-compliance budget.

Customs Entry Preparation

Entry Summary 7501 — HTS classified, valuation determined → ABI/ACE filing for licensed broker review.

HTS Classification

Product specs → HTSUS classification with GRI application, prior CBP ruling search.

USMCA Certificate of Origin

BOM + supplier origin → tariff-shift, RVC, de-minimis analysis. USMCA certificate in hours.

ISF (10+2) Preparation

Importer Security Filing data — extracted from PO, supplier invoice, vessel schedule — ACE-filed before lading.