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