Service

Duty Drawback & Tariff Refund Recovery

Recover up to 99% of import duties through drawback, and reclaim IEEPA tariffs after the 2026 Supreme Court ruling.

GingerControl files the full claim package, not just consults. We handle entry inventory across a 5-year look-back, prepare Unused Merchandise and Manufacturing drawback claims in ACE, apply for Accelerated Payment so refunds land in 30 to 45 days, and coordinate Post Summary Correction, protest, and CIT routes for importers reclaiming IEEPA tariffs after Learning Resources v. Trump.

  • 99% Duty Refund
  • Unused & Manufacturing Drawback
  • IEEPA Tariff Recovery
  • ACE Filing & Accelerated Payment

Service

Four Lanes of Recovery Work

Most engagements blend two or three of these lanes. We scope the mix during a compliance audit so the work matches your actual entry profile, not a generic template.

01

Eligibility & Feasibility Assessment

Find what is actually recoverable before committing to any filing work.

  • 5-year drawback look-back across all entry summaries
  • IEEPA tariff entry inventory with liquidation status by entry
  • Cash recovery estimate by claim type and entry batch
  • Data and document readiness audit, including export proof and bill of materials
02

Drawback Programs (Unused + Manufacturing)

File 99% refunds on imports later exported or used in US manufacturing.

  • Direct identification and substitution drawback under TFTEA, 8-digit HTS matching
  • Unused Merchandise drawback (19 CFR 190.31, 190.32) for re-exported imports
  • Manufacturing drawback (19 CFR 190.21, 190.22) for imported inputs in finished exports
  • Carborundum essential character analysis to defend the new article determination
See the HTS Classification Researcher
03

IEEPA Tariff Refund Recovery

Reclaim IEEPA duties after the 2026 Supreme Court ruling and the CIT nationwide refund order.

  • Entry liquidation status review, sorted by 180-day protest window
  • Post Summary Correction for unliquidated entries, refund through ACE
  • Protest under 19 USC 1514 for liquidated entries within window
  • CIT complaint coordination with outside counsel for entries outside administrative routes
04

ACE Filing, Privileges & Audit Defense

Full-service filing, not just consulting. We submit and defend the claim.

  • Accelerated Payment Program (APP) application, refunds in 30 to 45 days vs 314
  • Drawback Compliance Program (DCP) and Waiver applications
  • CF-28 and CF-29 response packages and audit support
  • 3-year document retention and post-liquidation reconciliation

Field Note

The Tariff Recovery Stack: Drawback, PSC, Protest, CIT

Most importers will get their IEEPA refund automatically once CBP completes its phased rollout. The ones who will not are the ones who stop paying attention to entry liquidation status. Once an entry is liquidated, the 180-day protest window under 19 USC 1514 starts running, and a missed deadline shifts the refund route from administrative to litigation, where the cost-to-recovery ratio collapses. Drawback sits at the end of the recovery stack because the 5-year look-back is the most forgiving, but a smart program works the stack in reverse: IEEPA first sorted by liquidation date, then PSC, then protest, then drawback. The order is not optional. Working drawback first while IEEPA windows close is the most common way importers leave money behind.

How We Work

From Compliance Audit to Refund

A typical engagement runs four to ten weeks from compliance audit to first claim filing, with ongoing operations afterwards for repeat cycles.

  1. 01

    Compliance Audit

    Thirty minutes to understand your import volume, export reflow, IEEPA tariff exposure, and current broker setup.

  2. 02

    Entry Inventory & Feasibility

    Five-year drawback scan, IEEPA tariff paid totals, and a sorted list of entries by liquidation status so deadlines are not missed.

  3. 03

    Strategy & Privilege Setup

    Pick claim types, file APP and DCP for drawback, choose PSC vs protest vs CIT route per IEEPA entry batch.

  4. 04

    Filing & ACE Submission

    Prepare claim packages, file electronically in ACE, submit protests, coordinate with outside counsel where complaints are needed.

  5. 05

    Operations & Audit Support

    Refund tracking, CF-28 and CF-29 response, document retention for 3 years post-liquidation, and recurring drawback cycles.

Who We Serve

Three Profiles That Fit Best

01

High-Volume Importers with Re-Export Flow

Retailers and distributors that import into US distribution and re-export a meaningful share. Unused Merchandise drawback typically recovers six to seven figures annually once the program is operationalized.

02

US Manufacturers Using Imported Inputs

Producers that import components or raw materials and ship finished goods abroad. Manufacturing drawback with substitution under TFTEA is often the single largest recovery for this profile.

03

IEEPA-Affected Importers (2025 to 2026)

Any importer that paid IEEPA-era reciprocal tariffs, especially those with entries approaching or already past the 180-day protest window. CBP phased refund covers part of the population, the rest needs active filing.

Frequently Asked

Duty Drawback & Refund Questions

What is the difference between duty drawback and IEEPA tariff refund?

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Duty drawback is a statutory program under 19 USC 1313 that refunds up to 99% of duties on imports later exported or used in US manufacturing. It has a 5-year look-back and requires either direct identification or TFTEA substitution. IEEPA tariff refund is a separate mechanism triggered by the 2026 Supreme Court ruling in Learning Resources v. Trump, which held that IEEPA does not authorize unilateral tariffs. Refunds go through Post Summary Correction, protest, or CIT complaint, not drawback. The two run in parallel, and most importers eligible for both need to work them in the right order to avoid missing deadlines.

How far back can I claim?

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Drawback has a 5-year look-back from the date of export, regardless of when the import happened, so most entry summaries from 2021 onward are in scope. IEEPA refund timing depends on entry liquidation status. Unliquidated entries can be corrected via Post Summary Correction. Liquidated entries have a 180-day protest window under 19 USC 1514. Once that window closes, the route shifts to CIT complaint or waiting on CBP's phased automatic refund.

Do you file the claims, or just consult?

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We file. GingerControl handles the full claim package end to end: ACE electronic submission for drawback claims, Accelerated Payment Program applications so refunds land in 30 to 45 days, Post Summary Correction and protest filings for IEEPA entries, and document packages for CF-28 and CF-29 audit responses. CIT complaints require coordination with outside customs counsel, which we manage on your behalf.

I already paid IEEPA tariffs in 2025. Will CBP refund me automatically?

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Some of it, depending on entry status and CBP's phased rollout. Judge Eaton's March 4, 2026 CIT order requires CBP to refund all importers, but the implementation has phases and known exclusions. The first phase covers most formal and informal entries. A second phase covers entries with antidumping or countervailing duties, suspended or extended liquidation, and other special cases. We map your entries against the rollout phases and file PSC or protest for anything that risks falling through.

How does this work with my existing customs broker?

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We coordinate, we do not replace. Your broker continues to file new entries. We layer the recovery work on top: pulling entry data through the ACE Portal, preparing claim packages, filing drawback and refund claims, and responding to CBP requests. Brokers without a dedicated drawback specialist often welcome the support, and we hand off any operational pieces back to the broker for ongoing entries once the recovery program is running smoothly.

Talk to Us About Your Duty Drawback & IEEPA Refund Opportunity

Talk to Us About Your Duty Drawback & IEEPA Refund Opportunity

Talk to Us About Your Duty Drawback & IEEPA Refund Opportunity

Tell us about your import volume, IEEPA tariff exposure, and export flows. We will reply within one business day with whether there is a recoverable claim and a proposed next step.

Send us a message

Fill out the form and a member of our team will get back to you within one business day.

We typically respond within one business day.

Email Us

For general inquiries, partnership opportunities, or product questions:

chen@gingercontrol.com

Existing Customers

Already using GingerControl? Log in to your account for support:

app.gingercontrol.com

Office

Unit 12-324, 701 Tillery Street
Austin, TX 78702
United States

Compliance Reminder

This is an HTS classification researcher. Results are for general reference, educational, and planning purposes only, designed to enable better communication between trade compliance teams, importers, and licensed customs brokers. Per CBP Ruling HQ H290535, providing HTS classifications beyond 6 digits for specific imports constitutes "customs business" under 19 U.S.C. § 1641. Do not use these results directly in customs entry documents without independent review by a licensed customs broker.

Read full compliance disclaimer

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