by James Rodgers, CEO | August 22, 2018

The Trade Facilitation and Enforcement Act (TFTEA) went into effect earlier this year and has been a boon to any company that imports or exports as it allows for a much more streamlined process for claiming substitution drawback using 8-digit classifications.

I am confident that there is no other firm in this country as prepared to take full advantage of this law than J.M. Rodgers. We have been preparing for years to not just keep our software and operations up to date filing claims, but to truly grab this bull by the horns and use it to the fullest for our clients. We’ve embarked on a years-long project to both maximize our clients’ internal returns and also to find additional opportunities through our internal databases. These are all centered around the use of ACE.


ACE is the Automated Commercial Environment, Customs’ “one window” for all trade information. Beyond new drawback regulations, the other major part of TFTEA was the increased usage and resources that are being put into ACE.

ACE gives importers and exporters full visibility of all their shipments across all brokers and service providers. An importer can see all their shipments the same way Customs would, able to check their classifications, duties paid, and other information.

We request limited ACE access through the online portal for all our clients so that we can get a full view of their imports and exports to make sure we are not only fully maximizing their returns, but are using the data for quality checks on the claims we file. Because substitution claims can be made using 8-digit HTS numbers (which are in ACE) and don’t need part numbers (which are not in ACE), under the new regulations, we can use ACE data to determine a clients’ potential.

Internal and External Matches a 1-2-3 Process

We have created a database of HTS classifications of all our clients, giving us the capability to find our clients previously unknowable avenues for refunds. By working with our JMR Trading arm that allows us to match unrelated importers and exporters to file claims, JM Rodgers is making exceptional use of new regulations

JMR’s experts have mastered this to a 1-2-3 process:

1.Sign a non-disclosure agreement
2.Give JMR limited ACE access
3.Get Matched

Once granted, we determine all of our clients’ internal matches, meaning any drawback opportunities they have on their own imports and exports that can be easily claimed. Then we check the remainders against our internal database and will inform our clients if any opportunities exist to discuss drawback trading.
This database is constantly being updated, and so once we have this information we will continually be checking to immediately inform our customers of new money they can pursue through drawback.

Next Step

To see if you qualify for drawback on your own imports and exports or possibly through trading opportunities, please contact Andrew Galloway, VP of Sales, at or 973-726-5340. Through a simple ACE analysis, we can help you find money for your bottom line.