Savings Under TFTEA Via Drawback Trading

Case Study

JMR discovered over a million dollars in refunds under TFTEA that neither importer nor exporter had expected to realize.


Global supplier, importer, exporter, and distributor of chemicals, minerals, and raw materials.


An existing customer (Client 1) had substantial imports but minimal exports upon which to claim drawback.


    Under the provisions in the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA), we now can match tariff codes on an 8-digit level for drawback purposes. Based on this law, using our drawback trading concept, we can match imports from Client 1 with exports from Client 2, even if they don’t have an existing commercial relationship.

    Under TFTEA, the rules for matching imports to exports have changed from “Commercially Interchangeable,” a very high standard to meet, to interchangeability based upon classification under common tariff subheadings, which is a much easier test to complete.

    We identified another customer (Client 2) who had excess exports, which, under the new TFTEA interchangeability rules, could be matched up with the excess imports of Client 1. We then analyzed each party’s excess imports and exports inventory to identify those that could qualify for drawbacks under an adequately structured arrangement.

    We fully appreciate that importers and exporters guard their commercial transaction details zealously. Therefore, it is our practice to obtain NDAs that give us the necessary access but protect each party from the disclosure of their details to the other. Our NDAs only permit disclosure when a Customs inquiry requires it under pre-established rules and as vetted by our trade counsel.

    Establishing a commercial relationship, which can be pre-existing or created, is necessary to make a drawback claim. Therefore, employing a drawback trading concept, we demonstrated the required commercial relationship between the import rich company (Client 1) and export rich company’s (Client 2) transactions so that we could file the drawback claims resulting from their combined transactions.


    JMR discovered over a million dollars in refunds that neither importer nor exporter had expected to realize. JMR is in a unique position as the only A-to-Z drawback provider able to facilitate this kind of trading scenario under TFTEA, giving customers access to drawback refunds that their transactions histories hadn’t identified.


    Freight Management

    Freight Management

    Client An importer of toys, hobby goods, and giftware that supplied the country’s largest retailers.Challenge Our client had been taking advantage of being a beneficial cargo owner (BCO) and signed direct contracts with steamship lines for many years. Their volume of...

    Fraudulent Claims Cleanup

    Fraudulent Claims Cleanup

    Client A manufacturer of engineered and forged metal products.Challenge The customer contracted with a duty drawback specialist specializing in the metal and manufacturing industry. As a heavy user of titanium, a valuable and high-duty product, the returns available...

    Freight Forwarding Services Saving Time and Money

    Freight Forwarding Services Saving Time and Money

    Client Major supplier of a variety of civilian and military aerospace components.Challenge A major customs brokerage client was experiencing issues on the small parcel shipment part of their supply chain that a primary small pack service provider was handling. They...

    A Tradition of Excellence

    J.M. Rodgers Co., Inc. is a family-owned and operated business with a rich tradition of serving and providing unparalleled support to our valued customers. In operation since 1952, J.M. Rodgers Co., Inc. is a recognized leader in global logistics specializing in Customs Brokerage, Freight Forwarding, and Duty Drawback.

    ISO 9001:2015 certification seal
    ISO 14001:2015 certification seal
    Customs Trade Partnership Against Terrorism (CTPAT) logo
    Lean Six Sigma White Belt logo
    Certified Transportation Network logo

    Find Out If You Qualify For Duty Drawback

     If you or your business imports and export goods to and from the United States, it’s possible that  you may qualify for duty drawback, which is a 99% refund on goods imported into the United States that are subsequently exported. Even if you don’t do both, you may still be able to qualify as long as importing and exporting happen along your supply chain.