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Trade Compliance
On Demand
March 10, 2022
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Duty Drawback 201: Manufacturing Substitution Drawback and Bills of Material

Dan Gardner

Solutions Consultant, 3rdwave

Grant Sernick

Director of Sales, 3rdwave

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March 10, 2022 2:00 PM
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Whereas duty drawback remains an attractive option for companies to recover duties paid on imported goods that are subsequently exported, the drawback provisions found in the Trade Facilitation & Trade Enforcement Act of 2015 (TFTEA) raised the bar on how filers can qualify for a duty refund. With updates published in “Modernized Drawback” (19 CFR Parts 181, 190 & 191), filers of all types know that the level of detail they must now provide in support of a drawback claim is considerably greater. 

Filers have also discovered that TFTEA has not made their job, the preparation of data needed by their drawback broker, any easier. The validation of data across multiple sources, from ERP to ACE to Broker data has become more complex, even for the simplest of entries. Add in the additional requirement for inventory lots (J1) or Bills of Material (Manufacturing), the difficulties related to data compound, creating a level of complexity that most organizations are not capable of overcoming.

In recognition of the above, 3rdwave is conducting a 3-part Webinar Series entitled, “Duty Drawback in the TFTEA Era: Three Solutions to Three Very Specific Challenges”. During each webinar, we will focus on one especially demanding data challenge associated with a specific type of drawback entry and then explain how 3rdwave’s drawback software solution helps to alleviate the burden of manually mining, aligning and refining data requirements.

Part 1: Manufacturing Substitution Drawback and Bills of Material

Companies that engage in Manufacturing Substitution Drawback must submit Bills of Material that detail the specific makeup of finished goods. For some organizations, the ability to identify the components, both imported and domestically sourced inputs, that are substantially transformed into an entirely new product is a real challenge for certain organizations. When identifying BOMs is not the challenge, connecting and validating this data against import and export records is often insurmountable.

In this webinar, we’ll analyze the complexities associated with meeting the BoM submission requirement and how the 3rdwave drawback solution automates the entire process.

Register for Part 2: Unused Merchandise Substitution Drawback and the “Other, Other” Problem

Register for Part 3: Maximizing Your Drawback Claim While Building a Better Relationship with Your Drawback Broker

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Dan Gardner
Solutions Consultant, 3rdwave
Dan has both hands-on experience as V.P. of Logistics for a mid-sized importer and as a senior executive with several large 3PLs. In addition to his professional experience, Dan is a licensed customs broker, a professor of supply chain management, certified in Production & Inventory Management (CPIM), and a Black Belt in Six Sigma. As an author, Dan’s work has been featured in The Journal of Commerce, APICS Magazine, CSCMP Global Perspectives, and Inbound Logistics magazine.
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Grant Sernick
Director of Sales, 3rdwave
Grant is responsible for Sales and Business Development at 3rdwave. A thought leader and writer, Grant is an expert at helping BCOs organize their data and processes to automate and control operational tasks, while making the data available to the broader organization’s business processes, analysis, and reporting. Grant has a Mechanical Engineering degree from Queen’s University in Kingston, Ontario, and an MBA from the Ivey School of Business at Western University in London, Ontario.
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