Why one-path workflows under-recover
Many drawback programs pick a provision early and force the data into that path. That can leave money behind. A high-volume importer may have one product family that fits unused merchandise substitution, another that needs manufacturing drawback, a rejected goods stream, and tariff-heavy entries that require Chapter 99 reporting.
Optimization is the process of evaluating those paths together.
Optimization questions
| Question | Why it matters |
|---|---|
| Is exact traceability available? | Direct identification may be strongest when lot, serial, or inventory lineage is clean. |
| Is substitution available? | Substitution can expand recovery when exact traceability is weak but statutory matching is available. |
| Is manufacturing involved? | Manufacturing drawback may unlock recovery for imported inputs used in exported articles. |
| Was merchandise rejected? | Rejected merchandise drawback may apply where goods are defective as imported, nonconforming to sample or specifications, shipped without consent, or qualifying retail returns. |
| Are petrochemical rules relevant? | Special petroleum and petrochemical rules may create a different matching framework. |
| Which duties are recoverable? | Ordinary duties, MPF, HMF, Section 301, Section 122, Section 232, and excise taxes need separate treatment because some are recoverable, some are conditionally recoverable, and some are not recoverable under specific programs. |
| What creates the best audit record? | The highest estimate is not useful if the evidence cannot support the claim. |
Pax approach
Section 232 is not one bucket: pharmaceuticals and timber or lumber differ from metals, automobiles, semiconductors, and other programs.
Pax models candidate matches across provisions, flags evidence gaps, compares refund potential, and routes claims through expert review. AI helps normalize data and surface candidates, while licensed customs brokers and drawback specialists decide what can be filed.