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Charter’s Comments to Proposed Rulemaking (NPRM) and Drawback Regulations

September 26, 2018

On September 17, 2018, Charter Brokerage submitted , comments in response to the Notice of Proposed Rulemaking (“NPRM”) issued by Treasury and Customs on August 2, 2018. Charter participated with the Trade Support Network and various associations during the 10-year legislative process that produced TFTEA. Charter was also involved with a working group in partnership with CBP to develop the above referenced regulations. CBP promised that there would be no “surprises” within the NPRM, unfortunately that was not the case. In particular, Treasury added a number of new provisions that were never previously discussed. The majority of our comments relate to the proposed regulations related to the limitation on Federal excise taxes eligible for duty drawback. Please see the brief summary below of Charter’s comments to the NPRM.

  • Removal of the limitations on Federal excise taxes;
  • Corrections to drafting errors related to 1313(p);
  • Correcting the effective dates;
  • Eliminating new import bond conditions related to drawback claims;
  • Support of the “per unit average” method;
  • Eliminating the “first filed” and “mixed use” use provisions;
  • Proposing further modernization of various aspects of the drawback claim process.

We encourage you to read Charter’s comments in their entirety by clicking the button below.

If you have any questions or would like to discuss our comments, please do not hesitate to reach out to any member of the Drawback team at Drawback@charterbrokerage.net.