Most companies leave duty drawback money on the table because nobody told them they qualified.

Duty drawback is a federal program that refunds import duties on goods that are subsequently exported - and most cross-border manufacturers and distributors either do not know they qualify or have never been through a proper program qualification process. CIMA International identifies drawback opportunities and structures compliance programs for companies operating across the U.S.-Mexico border.

What duty drawback is and who qualifies

Duty drawback is a U.S. Customs and Border Protection program that allows companies to recover up to 99% of duties, taxes, and fees paid on imported goods that are subsequently exported or destroyed. The program has been in place since 1789 and covers a range of scenarios - manufacturing drawback, unused merchandise drawback, and rejected merchandise drawback - that apply across different business models.

Companies that import components and export finished goods, import merchandise and re-export it to Mexico or other markets, or manufacture in Mexico and bring finished goods into the U.S. for re-export all have potential drawback exposure. The complexity of the program means that most companies with valid claims either never file or leave significant recovery on the table through improper structuring.

Drawback recovery is not a theoretical benefit - it is real money that was paid to Customs and can be legally recovered. The question is whether your trade flows are structured to capture it.

USMCA (T-MEC) compliance is a related priority. The agreement's rules of origin determine whether goods manufactured in whole or in part in Mexico qualify for duty-free treatment - and qualification requires documentation, record-keeping, and product classification work that is distinct from standard import/export compliance. CIMA provides USMCA qualification analysis and the documentation structure companies need to claim preference.

Trade compliance and drawback engagements

  • Drawback qualification assessment - review of trade flows, import records, and export documentation to identify which drawback program types apply and estimate the recovery opportunity
  • Program structuring - working with specialized drawback counsel to design the claim structure, establish the record-keeping system, and manage the CBP filing process
  • USMCA/T-MEC qualification - rules of origin analysis, product classification review, and the supplier certification documentation required to claim preferential duty rates
  • Import/export compliance review - assessment of current compliance with CBP requirements, Mexican SAT import obligations, and the documentation standards that protect against audit exposure
  • Tariff classification and HTS analysis - review of harmonized tariff schedule classifications for products moving across the border, identifying misclassifications and optimization opportunities
  • Cross-border trade structure - guidance on entity structure, transshipment, and the legal framework for companies manufacturing in Mexico and selling in the U.S. market
  • Maquiladora and IMMEX program guidance - assessment of IMMEX program eligibility and the operational requirements for companies considering Mexico manufacturing under the program
  • Customs broker coordination - working with existing customs brokers to align documentation practices with drawback and compliance program requirements
Why This Matters at Entry

Trade compliance is a day-one decision

Companies that structure their cross-border trade correctly at entry - with the right HTS classifications, the right USMCA documentation, and the right drawback eligibility built into their import/export flows - recover money and avoid exposure. Companies that address trade compliance as an afterthought discover the problem at audit, by which point the misclassification history, the unclaimed drawback opportunity, and the documentation gaps are all compounding problems.

CIMA includes trade compliance and drawback assessment in market entry work specifically because the decisions made at entry determine the cost structure and the compliance exposure for the life of the operation.

Start with the decision you are facing.

If you are importing from or exporting to Mexico, the first question is whether your trade flows are structured to recover what you are owed and avoid what you are not.

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