Unlocking $1M+ in Annual Duty Refunds Through the U.S. Drawback Program

An industrial manufacturer approached Customs Support Group to explore potential duty recovery under the U.S. drawback program. Like many companies, they had long assumed the process was too complex and time-consuming to pursue. But with rising duties and increasing pressure on margins, they were ready to revisit the opportunity.

CSG’s tailored approach helped the client unlock more than $1 million in refunds while establishing a sustainable process that required minimal ongoing effort from internal teams.

This mission was carried out by the CSG’s Trade Advisory team under the direction of Sean Miner (US Director) and Thibaut Grandjean-Miner (Head of Engagements).

Unlocking Hidden Capital: Navigating the Complexities of Duty Drawback

This U.S.-based industrial manufacturer had long paid millions in import duties on globally sourced components. Their leadership team suspected there might be room to recover some of these costs—but internal assumptions about complexity and resource constraints had kept the drawback program off the table. As tariff expenses increased, they contacted CSG to explore whether duty drawback might be viable.

We quickly confirmed that the client had matching import and export activity under the same HTS codes, making them a strong candidate for Unused Substitution Drawback. Importantly, most of the duties paid were MFN and Section 301 duties—both eligible for refund. The initial opportunity analysis showed more than $1.5 million in annual duties potentially recoverable.

A Technical Roadmap for Multi-Year Duty Recovery

Regulatory Strategy

To maximize historical recovery and create a scalable process, CSG pursued a bundled CBP application strategy. We submitted:

• A One-Time Waiver of Prior Notice to provide the waiver on duties paid on exports over the past 5 years.

• A General Waiver of Prior Notice to provide the waiver future shipments.

• An Accelerated Payment application to secure faster refund timelines.

We hosted a kickoff session with the client’s compliance team to complete CBP’s required questionnaire quickly and accurately. While it took approximately 3 months to receive approval, the upfront preparation streamlined the process and avoided delays.

Data Gathering & Coordination

The project’s complexity increased during the data phase. We worked with the client’s IT team to extract export documentation from their SAP system and reached out to multiple freight forwarders for shipment proofs. To prioritize, we focused on the two largest forwarders covering the majority of export volume. When one forwarder failed to provide the required BOLs, CSG escalated the request to their account manager, ultimately securing full compliance documentation.

Data Validation & Mock Audit

DOJÖ’s internal data team cleaned and transformed the import and export data, checking for:

• HTS matches and proper export dates

• Eligibility of duties (excluding Section 232)

• MPF/HMF validation

• Quantity alignment

We also conducted a mock CBP audit, issuing a document request mirroring what CBP typically sends and reviewing each response with the client to ensure traceability. This step gave the client confidence and prepared them for any post-submission review.

Measurable Financial Impact and Strategic Value Creation

Major Duty Refund Secured for our Client:

The initial claim submission covered 5 years of past activity and yielded:

• $850,000 in recovery under Accelerated Payment

• Refund received in under 30 days

Today, the client maintains a quarterly claim cadence, averaging $250,000 per quarter, or projected around $1 million annually in recovered duties. The compliance department, once viewed as a cost center, now delivers measurable financial value to the business. Leadership has expressed strong support, and CSG is currently evaluating opportunities to expand the program into manufacturing drawback and third-party claims.

Sustainable Compliance and Future Scalability

Accessing internal and third-party data proved to be the biggest challenge—a common hurdle in duty drawback projects of this scale. Despite the initial lift, the client noted, “There was upfront effort, but now it runs like clockwork.” Drawing on this experience, the DOJÖ U.S. Duty Mitigation team now routinely incorporates mock audits and early documentation reviews as standard practice in major drawback engagements, ensuring smoother execution and faster impact.

The client continues to leverage CSG’s ongoing support model to submit and defend claims, while internal resources remain focused on core operations. The success of this project has also sparked interest across the client’s regional operations in expanding duty-saving initiatives.

——————–

Disclaimer:

We take our clients’ confidentiality very seriously. While we have changed their names, the results are real. All our case studies are derived from real cases. Feel free to contact our experts to obtain referrals from our clients about the value creation of our services. You will then be able to see the results firsthand.

Article originally published by DOJO Consulting Group on www.welcometodojo.com, now part of Customs Support Group.