Many changes were introduced with 19 C.F.R 190 that will impact how everyone claims drawback.  Some of the major changes include the methodology and calculation for substitution drawback at the 8-digit HTSUS level, valuation of products for destruction, and allowances for electronic documentation and submission of drawback claims.

Yes, it is possible to recover those duties with the cooperation of the suppliers.  They will need to provide you with specific data elements to show a transfer of merchandise to your company for what was imported.

CBP only pays 99% of the duties as a duty drawback refund.  The remaining 1% is held to cover their costs to administer the program.  This has been in place since drawback was established in 1789. There are one or two minor exceptions

Drawback can be claimed on shipments to Mexico or Canada for certain types of unused and rejected merchandise and still receive a full drawback refund.  Identification of the exported merchandise back to its original importation is required for full recoveries using either a specific or accounting method.  Unused merchandise substitution drawback is not allowed on shipment to either CA or MX.

Manufacturing drawback and unused merchandise that is no longer in the same condition can be filed but these claims require a comparison of duties paid into the US to duties paid into CA or MX and you receive 99% of the lesser of two duties amout.

It is necessary to prove the date and fact of exportation, detail what was exported, and note the exporter of record.  CBP has outlined several sets of documents that can be provided including the master bill of lading, official postal records, and other supporting records kept in the normal course of business.

The Trade Facilitation and Trade Enforcement Act states that claimants for all drawback types have 5 years from the date of import to the date of filing the claim.  This 5-year window incorporates all imports, manufacturing details and exports as well as the claim filing date.