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CBP Issues New General Manufacturing Component Parts Drawback Ruling

Drawback filers have a new option for drawback claims involving manufacturing component parts, CBP said in a general ruling that was included in the April 22 Customs Bulletin. The ruling follows broad changes to drawback included in the Trade Facilitation and Trade Enforcement Act, CBP said. The agency said it recently received an industry request to remove some pre-TFTEA requirements included in the General Manufacturing Drawback Ruling from 1981.

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The 1981 ruling included language for “substitution on the basis of the same part number,” which is “no longer necessary based on the new substitution standard for manufacturing drawback claims pursuant to TFTEA,” the trade told CBP. “Upon review of this request, CBP has created a new Simplified General Manufacturing Component Parts Ruling that allows for substitution under 19 U.S.C. 1313(b) solely under the same 8-digit subheading of the HTSUS,” the agency said.

Companies “may now file for a component parts ruling” under the old ruling “or this new simplified ruling,” CBP said. “Manufacturers and producers who are currently authorized under the original T.D. 81–300 and seek to operate under this new simplified drawback ruling must apply to operate under the latter,” the agency said.

Among other requirements, the manufacturer or producer “must identify all the imported and substituted component parts by description that will be used within the Process of Manufacture or Production of the exported (or destroyed) article,” it said. The substituted parts “used in producing the exported (or destroyed) articles on which drawback is claimed must be classifiable under the same 8-digit HTSUS classification number as the designated components,” it said. “Specifications, drawings, or other documentation describing the substituted components maintained in the normal course of business will be maintained and made available for CBP Officials to verify classification of products. In order to obtain drawback it is necessary to prove that the merchandise, which is to be substituted for the imported merchandise or drawback products, is classifiable under the same 8-digit HTSUS classification.”