Service
Duty Drawback Recovery & Filing
Recover up to 99% of duties paid on imports later exported or used in US manufacturing.
GingerControl files the full claim package end to end, not just consults. We inventory every entry summary across the 5-year statutory look-back, prepare Unused Merchandise and Manufacturing drawback claims in ACE, apply for Accelerated Payment to shorten the refund cycle, and defend the program through CBP audits.
- 5-Year Look-Back Inventory
- Unused & Manufacturing Drawback
- ACE Filing with Accelerated Payment
- Carborundum & TFTEA Substitution
Related service
Reclaiming IEEPA tariffs after the 2026 Supreme Court ruling is a separate workstream, and now lives on its own page.
Open the IEEPA Refund serviceService
Four Lanes of Drawback Work
Most engagements blend two or three of these lanes. We scope the mix during a compliance audit so the program matches your actual entry profile, not a generic template.
Eligibility & Feasibility Assessment
Find what is actually recoverable before committing to any filing work.
Unused Merchandise Drawback
Refund duties on imports later exported or destroyed in the same condition.
See the HTS Classification ResearcherManufacturing Drawback
Refund duties on imported inputs used to make exported finished goods.
ACE Filing, Privileges & Audit Defense
Full-service filing and program operations, not one-off consulting.
Field Note
Most Drawback Programs Underperform Because of Records, Not Eligibility
The companies that leave drawback on the table are rarely the ones without exports or without imports. They are the ones whose bill of materials does not match the entry summary cleanly, whose export proof lives in a freight forwarder's inbox instead of a structured file, and whose ACE access is gated through a broker who is not credited as the drawback filer. By the time CBP issues a CF-28 asking how a finished export traces back to a specific imported lot, the answer either exists in the data or it does not. The work we do up front is unglamorous, mapping BOMs to entry-level HTS codes, building export-to-import correspondence files, applying for APP and DCP privileges before the first claim, and putting the recurring cycle on a calendar. The filing itself is the easy part. The records are the program.
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.
- 01
Compliance Audit
Thirty minutes to understand your import volume, export reflow, manufacturing flows, and current broker setup.
- 02
Entry Inventory & Feasibility
Five-year scan of entry summaries against export records, a cash recovery estimate by claim type, and a data readiness check on BOMs and export proof.
- 03
Strategy & Privilege Setup
Pick the claim types that fit your flows, file Accelerated Payment and Drawback Compliance Program applications, and structure the recurring cycle.
- 04
Filing & ACE Submission
Prepare claim packages, file electronically in ACE, coordinate with your broker on entry data, and submit Carborundum or substitution justifications when needed.
- 05
Operations & Audit Support
Refund tracking, CF-28 and CF-29 response, document retention for 3 years post-liquidation, and recurring drawback cycles with quarterly reviews.
Who We Serve
Three Profiles That Fit Best
High-Volume Importers with Re-Export Flow
Retailers and distributors that import into US distribution and re-export a meaningful share. Unused Merchandise drawback is often a recurring recovery channel once the program is operationalized.
US Manufacturers Using Imported Inputs
Producers that import components or raw materials and ship finished goods abroad. Manufacturing drawback with TFTEA substitution is often the single largest recovery for this profile, especially in chemicals, electronics, and metals.
Apparel, Footwear & Textile Importers
High-duty categories with significant returns, reverse logistics, and re-export volume. Unused drawback combined with rejected merchandise claims can recover meaningful cash on entries already filed years back.
Frequently Asked
Duty Drawback Questions
What is duty drawback, and how is it different from an 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, requires either direct identification or TFTEA substitution, and is filed electronically through ACE. IEEPA tariff refund is a separate mechanism triggered by the 2026 Supreme Court ruling in Learning Resources v. Trump, and it runs through Post Summary Correction, protest, or CIT complaint, not drawback. The two often run in parallel for the same importer, but they live in different parts of the recovery stack. See our dedicated IEEPA Refund service for the IEEPA-specific work.
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 five years ago through today are in scope. The clock runs from the export, not the import, which means imports paid many years earlier can still feed a current claim as long as the export is within the window.
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, Accelerated Payment Program applications to shorten the refund cycle, Drawback Compliance Program and Waiver applications for privilege setup, CF-28 and CF-29 audit responses, and recurring claim cycles after the first refund lands. Consulting-only engagements without filing are rarely worth the overhead for either side.
What is the difference between direct identification and substitution drawback?
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Direct identification means the exported article is traced back to the specific imported merchandise that paid duty, usually by lot or serial number. Substitution under TFTEA lets you match imported merchandise to exported merchandise that shares the same 8-digit HTS classification, even when they are not physically the same goods. Substitution unlocked drawback for many companies whose inventory commingles imports and domestic stock and could not be physically traced. Direct identification typically yields a cleaner audit trail, substitution covers far more entries in practice.
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 drawback program on top: pulling entry data through the ACE Portal, preparing claim packages, filing in ACE as the drawback filer of record, and responding to CBP requests. Brokers without a dedicated drawback specialist often welcome the support, and we hand operational pieces back to the broker for ongoing entries once the recurring program is running smoothly.
Talk to Us About Your Duty Drawback Opportunity
Talk to Us About Your Duty Drawback Opportunity
Talk to Us About Your Duty Drawback Opportunity
Tell us about your import volume, export flows, and current customs broker setup. We will reply within one business day with whether there is a recoverable claim and a proposed next step.
Email Us
For general inquiries, partnership opportunities, or product questions:
chen@gingercontrol.comExisting Customers
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app.gingercontrol.comOffice
Unit 12-324, 701 Tillery StreetAustin, 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.
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