Tariff Refunds & Duty Recovery
Reclaim What
You've Overpaid
in Tariffs
In an era of escalating trade actions — from Section 301 duties on Chinese goods to Section 232 levies on steel and aluminum — businesses often pay more than the law requires. Azarvand Tax Law identifies and pursues every available avenue for duty recovery.
$0
Out-of-pocket cost for
initial review
initial review
3 Yrs
Typical drawback claim
lookback window
lookback window
180
Days to file administrative
protest after liquidation
protest after liquidation
Why This Matters Now
The Tariff Landscape Has Changed
Years of layered trade actions have created a complex matrix of duties that affect importers across virtually every industry. The legal framework for refunds is equally layered — and exploiting it fully requires knowing which mechanism applies to your specific situation. Our firm focuses exclusively on this intersection of tax law and trade regulation.
Recovery Pathways
Three Routes to
Duty Relief
Federal law provides distinct mechanisms for recovering duties, each with its own eligibility criteria, filing deadlines, and procedural requirements.
01
Drawback
Claims
Under the drawback statute, importers who export goods — either in their original imported form, after manufacturing, or as rejected merchandise — may recover up to 99% of duties paid. The Modernization Act expanded drawback eligibility and simplified substitution rules, making this one of the most powerful refund tools available.
19 U.S.C. § 131302
Administrative
Protests
When U.S. Customs and Border Protection makes an incorrect tariff classification, valuation determination, or liquidation decision, importers have 180 days from the date of liquidation to file a protest. A successful protest can result in a full or partial refund of duties paid, plus interest. We prepare and litigate protests at every level of the administrative process.
19 U.S.C. § 151403
Tariff Exclusion
Petitions
The Office of the U.S. Trade Representative has at various times opened exclusion processes for goods subject to Section 301 duties, and the Department of Commerce has administered exclusions for Section 232 steel and aluminum tariffs. Obtaining an exclusion — or qualifying under an existing one — can yield both prospective relief and retroactive refunds on past entries.
Trade Act of 1974 § 301 · TEA 1962 § 232Our Process
From Assessment
to Recovery
We handle every step so your team can stay focused on operations.
Step 01
Import Records Audit
We review your entry summaries, HTS classifications, and payment history to identify overpayments and viable claims.
Step 02
Strategy Selection
We recommend the optimal combination of drawback, protest, and exclusion strategies based on your specific import profile.
Step 03
Filing & Submission
We prepare and file all required documentation with CBP, the Court of International Trade, or the USTR as appropriate.
Step 04
Agency Response
We monitor agency dockets, respond to information requests, and advocate through every round of administrative review.
Step 05
Refund Receipt
Once approved, we ensure refunds are correctly issued and applied, and advise on prospective duty-saving measures.
Legal Framework
Grounded in
Statute & Precedent
Duty recovery is not speculative — it is grounded in federal statute and decades of trade law development. Below are the four foundational authorities that underpin our practice.
19 U.S.C. § 1313
Drawback & Refunds
The core drawback statute authorizes recovery of duties, taxes, and fees on imported merchandise that is subsequently exported or destroyed. The Trade Facilitation and Trade Enforcement Act of 2015 substantially modernized the drawback system, broadening substitution rights and streamlining claims procedures. Claims must generally be filed within five years of the date of importation.
19 U.S.C. § 1514
Protest Procedure
Any person adversely affected by a CBP decision on classification, valuation, rate of duty, or liquidation may protest that decision. Protests must be filed within 180 days of the date of liquidation. A denied protest may be pursued before the U.S. Court of International Trade under 28 U.S.C. § 1581, which holds exclusive jurisdiction over civil actions arising from the denial of a protest.
19 U.S.C. § 2411 — Section 301
Trade Act Investigations
Section 301 of the Trade Act of 1974 authorizes the President to impose tariffs in response to foreign trade practices deemed unfair. The USTR has administered exclusion processes under which companies may petition for product-specific relief, including retroactive refunds on duties paid while an exclusion petition is pending. We track USTR exclusion windows and file strategically.
19 U.S.C. § 1862 — Section 232
National Security Tariffs
Section 232 of the Trade Expansion Act of 1962 permits the imposition of tariffs on goods that threaten national security. The Department of Commerce has administered product exclusion processes for steel and aluminum imports subject to these tariffs. Approved exclusions are retroactive to the date of the exclusion request, creating refund opportunities for duties paid in the interim.
Who We Serve
Is Your Business Eligible?
Virtually any company that imports goods into the United States may have a duty recovery opportunity. The most significant claims tend to arise in industries heavily impacted by Section 301 and Section 232 actions — including electronics, industrial machinery, steel fabrication, automotive parts, and consumer goods sourcing from China.
Tariff recovery is also highly relevant to businesses engaged in manufacturing, where imported materials are transformed and re-exported. Manufacturing drawback under 19 U.S.C. § 1313(b) allows recovery of duties paid on imported materials that are incorporated into products that are subsequently exported — even where the exported product is commercially interchangeable with, rather than directly derived from, the imported material.
Companies that have undergone mergers, acquisitions, or supply chain restructuring may also have inherited unclaimed drawback rights. We conduct a thorough analysis of your corporate history and import records to surface every recoverable claim.
Even if a protest deadline has passed, there may be opportunities under prior disclosure procedures, ruling requests, or prospective classification changes that reduce future liability while we document the basis for any refundable overpayments.
Tariff recovery is also highly relevant to businesses engaged in manufacturing, where imported materials are transformed and re-exported. Manufacturing drawback under 19 U.S.C. § 1313(b) allows recovery of duties paid on imported materials that are incorporated into products that are subsequently exported — even where the exported product is commercially interchangeable with, rather than directly derived from, the imported material.
Companies that have undergone mergers, acquisitions, or supply chain restructuring may also have inherited unclaimed drawback rights. We conduct a thorough analysis of your corporate history and import records to surface every recoverable claim.
Even if a protest deadline has passed, there may be opportunities under prior disclosure procedures, ruling requests, or prospective classification changes that reduce future liability while we document the basis for any refundable overpayments.
Common Eligibility Indicators
- Goods imported from China subject to Section 301 duties (Lists 1–4)
- Steel or aluminum imports subject to Section 232 tariffs
- Exported finished goods incorporating imported materials
- Imported merchandise returned, destroyed, or rejected
- Disputes over HTS classification or dutiable value
- Entries liquidated within the last 180 days
- Annual import duties exceeding $50,000
Critical Deadline
Administrative protests under 19 U.S.C. § 1514 must be filed within 180 days of liquidation. Missed deadlines generally cannot be extended. Contact us promptly if a recent entry may have been incorrectly classified or assessed.
Start With a No-Cost Evaluation
We review your import history at no charge and provide a frank assessment of your recovery potential before any engagement. If there is a viable claim, we structure our representation so that our success is aligned with yours.
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