This week, U.S. Customs released data detailing how much they’ve collected overall on new duties. Since its implementation in March of 2018, just under $100 billion in tariffs on 301 duties have been brought in. These duties, paid on imports from China and Europe, are eligible for drawback refunds and represent a big opportunity for savings.

Many companies eligible for refunds have yet to file for drawback, as Customs estimates that billions of dollars in potential drawback gets left behind every year. Companies need to be thinking about starting a drawback program now, as time is running out for the chance to get all available refunds.

Drawback law allows claimants to use imports in a claim for up to five years from the time of import. That means in only a little more than a year and a half from now, the first 301 tariffs from 2018 will begin to expire and there will be no way to claim this money once that window closes. Once March 2023 comes and goes, there will be millions of dollars made ineligible for refunds, forever lost to potentially eligible claimants.

Because there is always some money falling off the table, the best time to evaluate an importer or exporter’s potential for drawback is always “right now.” However, with the huge surge of duties that came with the imposition of 301 tariffs, there is potentially a windfall of unclaimed refunds about to fall out of eligibility, representing millions in lost potential revenue.

Implementing a duty drawback program can take some time to complete. The time from the qualification stage of identifying refund potential to filing Customs applications can take weeks or even months. Any company that has potential eligibility for this kind of refund would be better served getting a jump on what is sure to be a rush as time runs out.

Don’t delay and let refunds that could impact your bottom line expire before acting. To discuss how J.M. Rodgers can help you determine if you’re eligible for duty drawback, please contact SVP Andrew Galloway at (973) 726-5340 or via email at

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