How Recent Trade Policy Changes Impact Duty Drawback Opportunities

Volatile trade policies bring new drawback opportunities alongside challenges. Understanding these shifts lets importers convert duty burdens into refunds.

Recent years delivered tariff swings (Section 301, Section 232), USMCA renegotiation, compliance changes, drawback modernization, and supply chain realignment—creating fertile ground for refunds.

Tariffs of 7.5–25% on ~$370B of Chinese goods dramatically raised duty spend. The upside: Section 301 duties are generally drawback-eligible via unused merchandise or substitution claims, creating outsized refunds.

Case study: an electronics distributor paying $850K annually in 301 duties recovered ~65% of those costs through Evana’s program.

USMCA preserved key NAFTA-era provisions (same-condition and manufacturing drawback) and uses TFTEA’s modern substitution standard. Integrated North American supply chains can still unlock significant refunds.

Steel (25%) and aluminum (10%) tariffs also qualify for drawbacks. Manufacturers exporting finished goods containing these materials can reclaim a substantial portion of the duty load.

Key reforms: simplified substitution via same 8-digit HTS, five-year filing window, mandated ACE e-filing. These changes opened drawback access to more businesses with lower admin burden.

Recommended approach:

1. Monitor policy updates continuously.

2. Integrate drawback thinking into sourcing/export planning.

3. Conduct five-year lookbacks before claims expire.

4. Strengthen documentation systems proactively.

China+1 diversification, nearshoring, and friend-shoring create transitional periods ideal for drawback programs, as imports span multiple origins and exports may increase.

Watch for environmental trade measures (e.g., carbon adjustments), digital trade duties, national security tariffs (critical minerals), and continued U.S.-China developments—all of which could reshape drawback categories.

Evana tracks policy changes, adapts client programs quickly, and provides strategic guidance so imports/exports stay optimized for refunds despite regulatory volatility.

Trade policy volatility amplifies the value of effective drawback programs. By staying informed and leveraging specialists, businesses can transform tariff costs into meaningful refunds and competitive advantage.