Independent Compliance Auditor · CBP HQ H272798

Three ways US importers recover overpaid duty.Most are using only one.

Duty Drawback. IEEPA Refunds. Section 301/232 Corrections. MyCustomsInfo® identifies every opportunity across your full entry history. Your licensed customs broker executes.

We identify. Your broker acts.

Map Your US Recovery Opportunities Download the US recovery checklist
5 years
Drawback lookback window
180 days
IEEPA protest window
85%
Drawback goes unclaimed
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Side-by-Side Comparison

The Three Recovery Mechanisms

Most US importers are aware of one of these. Very few are actively pursuing all three. Each has its own legal basis, qualification criteria, and filing window.

Duty Drawback

Legal basis19 U.S.C. §1313
Who qualifiesImporters who exported or destroyed goods
Time limit5 years from importation
Recovery cap99% of duties paid
Who filesLicensed customs broker
MyCustomsInfo® roleIdentifies qualifying entries, calculates quantum, prepares data

IEEPA Refunds

Legal basisCIT March 2026 order; Tariff Refund Act S.3905
Who qualifiesImporters who paid IEEPA tariffs
Time limit180 days from liquidation (protest)
Recovery cap100% of IEEPA duties
Who filesLicensed broker or trade attorney
MyCustomsInfo® roleMaps entries to tariff orders, tracks protest windows, prepares data

Section 301/232 Corrections

Legal basis19 U.S.C. §1514 (protest); 19 C.F.R. §173 (PSC)
Who qualifiesImporters with misclassification or missed exclusions
Time limit180 days from liquidation
Recovery cap100% of overpayment
Who filesLicensed broker or trade attorney
MyCustomsInfo® roleIdentifies misclassifications, prepares PSC data package

Regulatory Context

Why US Customs Is Different

In most jurisdictions, the line between compliance auditing and customs brokerage is a matter of convention or best practice. In the United States, it is a matter of statute. 19 U.S.C. §1641 defines “customs business” and reserves it exclusively for licensed customs brokers. This includes preparing, filing, or submitting entries, drawback claims, protests, and any other documents required by CBP. Violation carries penalties for both the importer and anyone performing unauthorized customs business.

This is not a bureaucratic preference. It is why the MyCustomsInfo® model is built around data, audit, and preparation, not filing. We do not prepare entries. We do not submit corrections. We do not file drawback claims. We identify the opportunity, quantify the recovery, and prepare the data package to the standard your licensed broker needs to act.

HQ H272798
January 2017 · Permissible

CBP Headquarters assessed the independent auditor model and found it permissible under 19 U.S.C. §1641. Post-entry compliance auditing, when performed by an entity that does not prepare, file, or submit entries, does not constitute customs business. This ruling is the foundation of our US operating model.

HQ H350722
January 2026 · AI Classification Boundary

CBP established that providing 6-digit HTS heading suggestions for general research is permissible, while 10-digit classification for a specific entry constitutes customs business requiring a licensed broker. This ruling clarified the boundary for compliance technology in the US market.

“We exist to make your licensed broker's work faster, more accurate, and more complete. Every data package we produce is built to the standard CBP expects a broker to submit.”

Time-Sensitive

The 5-Year Drawback Window Is Running

Most US importers with active manufacturing or re-export operations have unclaimed drawback going back five years. The entry history is in ACE. The work is identifying which entries qualify, matching them to export records, and calculating the quantum.

Under 19 U.S.C. §1313, your licensed broker can claim up to 99% of duties paid on imported goods that were subsequently exported or destroyed. But the clock started ticking on the date of importation. Every month this is deferred, more of the five-year lookback period is lost permanently.

MyCustomsInfo® scans your ACE entry history, matches import lines to export documentation, calculates the drawback quantum per entry, and delivers a broker-ready data package. Your broker reviews and files.

5 years
Maximum lookback from date of importation
99% recovery cap on duties paid
Applies to manufacturing drawback and unused merchandise
Requires matched import-to-export documentation
180 days
From liquidation to file a protest
100% of IEEPA duties recoverable
Protest filed under 19 U.S.C. §1514
Window is per-entry, not per-importer
Active Window

The IEEPA Protest Window Is Also Running

Entries being liquidated now under IEEPA tariff orders need to be reviewed against protest eligibility while the 180-day window is open. Once an entry liquidates and the protest window closes, the opportunity is gone. There is no extension.

Following the CIT March 2026 order and the legislative progress of the Tariff Refund Act (S.3905), the legal basis for IEEPA refund protests is clearer than at any point since the tariffs were imposed. But the window is per-entry. If your entries are liquidating now, you need to act now.

MyCustomsInfo® maps every entry in your ACE history against active IEEPA tariff orders, tracks liquidation dates, and alerts you before each protest window closes. The platform does this automatically.

Clear Division of Responsibility

What MyCustomsInfo® Delivers vs. What Your Broker Delivers

“We already have a customs broker. Why do we need this?” This is the first question every US prospect asks. Here is the answer.

MyCustomsInfo® Delivers

Independent compliance auditor

Full ACE entry history audit across all three recovery mechanisms
Identification of qualifying drawback entries with import-to-export mapping
IEEPA exposure mapping with per-entry liquidation date tracking
Misclassification and missed exclusion identification for Section 301/232
Recovery quantum calculation per entry and per mechanism
Broker-ready data packages built to CBP submission standards
Ongoing monitoring with automated alerts before protest windows close

Your Licensed Broker Delivers

Regulated customs business under 19 U.S.C. §1641

BReviews and validates the data package prepared by MyCustomsInfo®
BFiles drawback claims with CBP under 19 U.S.C. §1313
BSubmits protests under 19 U.S.C. §1514 for IEEPA refunds
BFiles Post-Summary Corrections under 19 C.F.R. §173
BManages CBP correspondence and liquidation follow-up
BConfirms recovery amounts and distributes refunds
BMaintains all broker records per 19 C.F.R. §111.23
CBP-Validated Compliance Model

Built to US Customs & Border Protection Standards

MyCustomsInfo® operates as an independent compliance auditor, not a customs broker. Our operating model has been validated against CBP Headquarters Ruling H272798 and the supporting ruling H350722. All US broker records are held in US-based AWS regions in compliance with 19 C.F.R. §111.23.

19 U.S.C. §1641 Compliant
Does not conduct customs business as defined under the statute
CBP HQ H272798
Primary ruling authority (Jan 2017)
US AWS Data Residency
Broker records per 19 C.F.R. §111.23
Case Studies

Duty Recovery Results From Real Engagements

See how multinational importers have recovered overpaid duties across UK, EU, and US customs regimes.

$610K+ Industrial manufacturer recovery$5.5M Assessment defense saving7:1 Average ROI

Frequently Asked Questions

Map Your Full US Recovery Opportunity.Your Broker Files the Claim.

Get a complimentary assessment of your ACE data across all three recovery mechanisms. We identify drawback, IEEPA refund eligibility, and Section 301/232 correction opportunities. Your broker handles the filing.

Map Your US Recovery Opportunities
Independent compliance auditor
CBP-validated model
No obligation assessment

US Regulatory Notice. MyCustomsInfo® is an independent compliance auditor. It does not conduct customs business as defined under 19 U.S.C. §1641. The specific tariff classification to be applied to any entry of merchandise is to be determined by a licensed Customhouse broker. MyCustomsInfo® output does not constitute entry preparation, classification advice, or customs broker services. Preparation and filing of Post-Entry Amendments, Post-Summary Corrections, protests, and drawback claims must be performed by a licensed customs broker. US broker records are held in US AWS regions in compliance with 19 C.F.R. §111.23. Primary authority: CBP HQ H272798 (January 2017). Supporting authority: CBP HQ H350722 (January 2026).