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How J.M. Rodgers Supports Clients During CBP Duty Drawback Audits

J.M. Rodgers' approach to supporting drawback clients during CBP reviews, including transaction reconstruction, documentation, methodology support, and regulatory responses.

CBP audit support is included as part of J.M. Rodgers' duty drawback service at no additional fee. When CBP reviews a client's drawback activity, our team can help identify the scope of the request, assemble supporting records, reconcile transactions, explain the applicable methodology, and support responses to CBP.

Because J.M. Rodgers is already involved in managing the underlying drawback program, the team brings existing knowledge of the client's data, documentation, methodology, and claim history into the review process.

Is CBP Audit Support Included With J.M. Rodgers' Duty Drawback Service?

Yes. J.M. Rodgers includes support for CBP duty drawback reviews and audits as part of its duty drawback service rather than treating audit assistance as a separate consulting engagement.

Because J.M. Rodgers is already involved in managing the client's drawback program, the team has familiarity with the program's methodology, source data, supporting documentation, claim history, and transaction flows before a CBP review begins.

This continuity can make it easier to identify the records and explanations needed to support claims under review.

What Does J.M. Rodgers Do When CBP Reviews a Drawback Claim?

The exact support provided depends on the type and scope of the CBP review.

J.M. Rodgers may assist with:

  • Reviewing the scope of CBP's request
  • Identifying the claims and transactions under review
  • Locating and organizing supporting records
  • Reconciling claim data to source information
  • Reviewing the applicable drawback methodology
  • Supporting explanations of calculations and merchandise relationships
  • Preparing responses to requests for records or information
  • Coordinating with the client and CBP, as appropriate
  • Identifying potential discrepancies that require additional review

The objective is to provide CBP with clear, organized support for the drawback activity being examined.

Responding to CBP Requests for Records and Information

CBP may request supporting records when reviewing individual drawback claims or conducting a broader audit.

J.M. Rodgers works with clients to determine which records are relevant to the request and how those records relate to the claims being reviewed.

Depending on the program, documentation may include:

  • Import entry information
  • Commercial invoices
  • Duty and fee data
  • Export records
  • Inventory records
  • Merchandise-transfer documentation
  • Manufacturing records
  • Bills of material
  • Production information
  • HTSUS classifications
  • Manufacturing drawback rulings
  • Destruction documentation
  • Claim calculations

J.M. Rodgers can help organize this information so the relationship between the source records and the filed drawback claim is clear.

Reconstructing and Supporting Selected Transactions

CBP may select specific transactions or claim lines for detailed review.

When that occurs, J.M. Rodgers can help reconstruct the transaction history supporting the claim.

Depending on the drawback methodology, this may involve tracing:

  • The designated import
  • Duties, taxes, and fees associated with the import
  • Inventory movements
  • Transfers between parties
  • Manufacturing or production activity
  • Substitute merchandise
  • Exportation or qualifying destruction
  • The resulting drawback calculation

The specific tracing requirements depend on the applicable drawback provision and methodology.

The goal is to demonstrate how the underlying business records support the information reported on the drawback claim.

Supporting Drawback Methodologies and Calculations

A CBP review may examine not only whether records exist, but whether those records support the drawback methodology used.

J.M. Rodgers can assist clients in explaining and documenting areas such as:

  • Direct Identification Manufacturing Drawback
  • Substitution Manufacturing Drawback
  • Direct Identification Unused Merchandise Drawback
  • Substitution Unused Merchandise Drawback
  • Rejected Merchandise Drawback
  • Manufacturing relationships
  • Bills of material
  • Merchandise transfers
  • Export or destruction relationships
  • HTSUS classification relationships
  • Applicable manufacturing drawback rulings
  • Claim calculations

For substitution and manufacturing programs in particular, supporting the methodology may require information from multiple systems and departments.

J.M. Rodgers works with clients to connect those records to the methodology used to prepare the claim.

Organizing Documentation for CBP Review

A strong audit response requires more than collecting documents. The records should be organized so the reviewer can understand how they support the transactions being examined.

J.M. Rodgers can assist with reviewing and organizing documentation such as:

  • Import records
  • Export records
  • Manufacturing data
  • Inventory records
  • Supplier and customer records
  • Merchandise-transfer documentation
  • Classification information
  • Claim calculations
  • Supporting certifications

Our team also reviews the relationship between the records and the claim data to identify inconsistencies or gaps that may require clarification.

Internal Claim Reviews Before an Audit Occurs

J.M. Rodgers operates in an ISO 9001:2015-certified Continuous Process Improvement environment and incorporates internal review procedures into its duty drawback process.

These procedures can include sample-based reviews of drawback data and supporting records designed to identify the types of discrepancies that could become relevant during a CBP Desk Review.

Depending on the program, internal reviews may examine issues such as:

  • Import and export data alignment
  • Merchandise tracing
  • HTSUS classifications
  • Bills of material
  • Production data
  • Merchandise transfers
  • Supporting documentation
  • Claim calculations

When recurring issues are identified, J.M. Rodgers can work with the client to investigate the cause and improve the underlying process.

This approach helps make audit readiness part of ongoing program management rather than something addressed only after CBP begins a review.

Supporting Communication With CBP

CBP reviews can involve requests for clarification regarding transactions, supporting records, claim calculations, or drawback methodology.

J.M. Rodgers can assist clients in preparing clear and consistent responses and can support communications with CBP when appropriate.

This may include:

  • Clarifying what information CBP is requesting
  • Preparing supporting documentation
  • Explaining the methodology used
  • Reconciling requested claim information
  • Addressing follow-up questions
  • Coordinating responses among the client, J.M. Rodgers, and other advisors when necessary

The client remains an important participant in the process, particularly when CBP requests records or explanations concerning internal business operations outside of J.M. Rodgers' direct control.

What Happens If CBP Identifies an Issue?

If CBP identifies a potential problem, the appropriate response depends on the nature of the issue and the transactions affected.

J.M. Rodgers can help the client evaluate:

  • Which claims or transactions may be affected
  • Whether additional supporting records are available
  • Whether the issue results from a data discrepancy
  • Whether the drawback methodology requires clarification
  • Whether a calculation needs to be reconciled
  • What information should be provided in response
  • Whether internal procedures should be adjusted going forward

An issue involving one transaction does not necessarily affect an entire drawback program. The potential impact depends on the underlying facts, methodology, documentation, and scope of the CBP review.

J.M. Rodgers does not control CBP's findings or guarantee a particular audit outcome, but our team works with clients to provide the documentation and program knowledge needed to respond effectively.

Why Does J.M. Rodgers' Ongoing Involvement Matter During an Audit?

J.M. Rodgers' audit support does not begin only after CBP contacts the client.

The same drawback team involved in developing, preparing, reviewing, and managing the client's program can also support the claims if CBP later examines them.

That means the team may already understand:

  • How the program was structured
  • Which drawback methodology was used
  • How source data is received and processed
  • How import and export transactions are connected
  • How manufacturing data is incorporated
  • How calculations are performed
  • What documentation supports the claims
  • How the program has changed over time

This institutional knowledge can be particularly valuable when CBP selects older transactions or complex claim relationships for review.

Supporting an Ongoing Compliance Program

Audit readiness is strongest when documentation and compliance procedures are maintained throughout the life of the drawback program.

J.M. Rodgers works with clients on an ongoing basis to support:

  • Accurate claim preparation
  • Consistent documentation
  • Data reconciliation
  • Regulatory methodology
  • Recordkeeping
  • Internal claim review
  • Program updates as business activity changes
  • Responses to CBP inquiries

The objective is to build a drawback process in which supporting records can be traced and explained when CBP requests them.

For an overview of the CBP review process itself, see What Happens During a CBP Duty Drawback Audit?

Next Steps

If your company receives a CBP request involving its duty drawback program, J.M. Rodgers can help identify the scope of the review, organize the relevant records, evaluate the affected transactions, and support the response process.

For existing J.M. Rodgers drawback clients, CBP audit and review support is included as part of our duty drawback service at no additional fee.

Disclaimer

This information is general in nature and does not constitute legal advice. The scope of CBP reviews and audits, records requested, potential findings, and appropriate responses depend on the specific facts, claims, transactions, and regulatory requirements involved.