| Title: | 1313(j)(2) |
|---|---|
| Date: | 1998-11-10 |
| To: | abi |
| Links: | previous, next |
TO : ALL ABI BROKERS.
FROM : LYNN RODRIGUEZ
SUBJECT : DRA-1313(j)(2)
DATE : 10/20/1998
OCTOBER 19, 1998
FO:TC:C:E:D LF/MC
TO: PORT DIRECTORS, BOSTON, NEW YORK, MIAMI, CHICAGO,
NEW ORLEANS, HOUSTON, LOS ANGELES, SAN FRANCISCO
ALL INTERESTED PARTIES
FROM: ASSISTANT COMMISSIONER
OFFICE OF FIELD OPERATIONS
SUBJECT: COMMERCIAL INTERCHANGEABILITY - 1313(J)(2)
SUBSTITUTION DRAWBACK
PASS TO: DRAWBACK CHIEFS AND DRAWBACK SPECIALISTS, CUSTOMS
LABORATORIES
TREASURY DECISION 98-16 DATED MARCH 5, 1998, REVISED THE CUSTOMS
REGULATIONS FOR DRAWBACK, PART 191. SUBPART C OF THE REVISED
DRAWBACK REGULATIONS ESTABLISHED UNIFORM POLICY AND INSTRUCTION FOR
BOTH CUSTOMS AND THE TRADE TO FOLLOW FOR DETERMINING THE COMMERCIAL
INTERCHANGEABILITY OF MERCHANDISE FOR DRAWBACK PURPOSES. THE
SUBSTITUTED MERCHANDISE EXPORTED OR DESTROYED FOR DRAWBACK NEED NO
LONGER BE FUNGIBLE (COMMERCIALLY IDENTICAL) WITH THE IMPORTED
MERCHANDISE. INSTEAD THE IMPORTED AND SUBSTITUTED MERCHANDISE
MUST BE COMMERCIALLY INTERCHANGEABLE. ALSO, THE NEW REGULATIONS HAVE
MORE CLEARLY DEFINED THE PARTY ENTITLED TO CLAIM DRAWBACK.
COMMERCIALLY INTERCHANGEABLE MERCHANDISE CAN QUALIFY FOR DRAWBACK IF
IT IS EXPORTED, OR DESTROYED UNDER CUSTOMS SUPERVISION, WITHIN THREE
YEARS AFTER THE IMPORTATION OF THE IMPORTED MERCHANDISE, AND IF THIS
COMMERCIALLY INTERCHANGEABLE MERCHANDISE IS NOT USED IN THE U.S
BEFORE SUCH EXPORTATION OR DESTRUCTION AND IS IN THE POSSESSION
OF THE PARTY CLAIMING DRAWBACK. THE NEW REGULATIONS REQUIRE A
DETERMINATION OF "COMMERICAL INTERCHANGEABILITY" FOR ALL CLAIMS FILED
UNDER 1313(J)(2).
MANY DRAWBACK CENTERS ALREADY HAVE PREDETERMINATIONS OF COMMERCIAL
INTERCHANGEABILITY OR BINDING RULINGS ISSUED BY OR&R FOR 1313(J)(2)
MERCHANDISE. THESE APPROVALS OF COMMERCIALINTERCHANGEABILITY
SHALL REMAIN IN EFFECT AND WILL NOT EXPIRE ONE YEAR AFTER THE
APRIL 6, 1998 EFFECTIVE DATE OF THE NEW REGULATIONS.
IN THE INTEREST OF ADMINISTRATIVE EFFICIENCY AND BECAUSE COMMERCIAL
INTERCHANGEABILITY IS NO MORE RESTRICTIVE THAN FUNGIBILITY, ALL PRIOR
UNREVOKED RULINGS FINDING MERCHANDISE TO BE FUNGIBLE MAY CONTINUE
TO BE RELIED UPON TO ESTABLISH COMMERCIAL INTERCHANGEABILITY AND
REAPPLICATION IS UNNECESSARY FOR THE SAME MERCHANDISE.
SPECIFIC REQUIREMENTS EXIST FOR QUALIFICATION FOR 1313(J)(2)
SUBSTITUTION DRAWBACK AND THEY ARE OUTLINED IN PART 191.32 OF
THE NEW REGULATIONS:
(1) THE CLAIMANT MUST HAVE POSSESSED THE MERCHANDISE THAT
IS EXPORTED WHICH IS ASSERTED TO BE SUBSTITUTED FOR THE
IMPORTED DESIGNATED MERCHANDISE, AND
(2) THE SUBSTITUTED MERCHANDISE MUST BE COMMERCIALLY
INTERCHANGEABLE WITH THE IMPORTED MERCHANDISE THAT IS
DESIGNATED FOR DRAWBACK, AND
(3) THE SUBSTITUTED MERCHANDISE EXPORTED OR DESTROYED MUST
NOT HAVE BEEN USED IN THE U.S. BEFORE ITS EXPORTATION
OR DESTRUCTION.
IN ORDER TO DETERMINE COMMERCIAL INTERCHANGEABILITY, CRITICAL
PROPERTIES OF THE SUBSTITUTED MERCHANDISE MUST BE EVALUATED BY
CUSTOMS AND SEVERAL FACTORS MUST BE CONSIDERED, INCLUDING, BUT NOT
LIMITED TO TO, GOVERNMENT AND RECOGNIZED INDUSTRY STANDARDS, PART
NUMBERS, TARIFF CLASSIFICATION AND VALUE. THERE ARE THREE WAYS FOR
A CLAIMANT TO OBTAIN A DETERMINATION.
(1) A NONBINDING PREDETERMINATION OF COMMERCIAL
INTERCHANGEABILITY OBTAINED DIRECTLY FROM A DRAWBACK
OFFICE WHERE CLAIMS WILL BE FILED FOR REPETITIVE CLAIMS
THE SAME MERCHANDISE ONLY.
(2) A FORMAL RULING FROM THE DUTY AND REFUND DETERMINATION
BRANCH, OR&R.
(3) A SUBMISSION OF ALL THE REQUIRED DOCUMENTATION NECESSARY
TO MAKE A COMMERCIAL INTERCHANGEABILTY DETERMINATION
WITH EACH INDIVIDUAL DRAWBACK CLAIM FILED.
REQUIRED INFORMATION
THE FOLLOWING IS A LIST OF ITEMS THAT MUST BE INCLUDED IN ALL REQUESTS
FOR COMMERCIAL INTERCHANGEABILITY DETERMINATIONS WHETHER IT ISTO BE
OBTAINED AS A PREDETERMINATION, A FORMAL RULING FROM OR&R, OR WITH AN
INDIVIDUAL DRAWBACK CLAIM:
(1) NAME, ADDRESS, AND INTERNAL REVENUE SERVICE (IRS)
NUMBER (WITH SUFFIX) OF THE APPLICANT
(2) A BRIEF EXPLANATION OF THE CLAIMANT'S BUSINESS
(3) A STATEMENT AS TO WHETHER THE COMPANY IS BOTH THE
IMPORTER AND EXPORTER OF THE MERCHANDISE WHICH WILL BE
THE SUBJECT OF THE DRAWBACK CLAIMS (I.E., FOR
VERIFICATION THAT DOUBLE SUBSTITUTION IS NOT TAKING
PLACE. UNDER 19 U.S.C. 1313(J)(2), MULTIPLE TRANSFERS OF
MERCHANDISE CAN TAKE PLACE, BUT ONLY ONESUBSTITUTION
IS ALLOWABLE). ENSURE THAT APPROPRIATE CERTIFICATES
OF DELIVERY HAVE BEEN ISSUED, AND ARE AVAILABLE UPON
REQUEST.
(4) A FULL DESCRIPTION OF WHAT IS IMPORTED AND WHAT WILL BE
SUBSTITUTED, INCLUDING THE SOURCE OF THE SUBSTITUTED
MERCHANDISE. INFORMATION SHOULD BE SUBMITTED
EXPLAINING ANY DIFFERENCES BETWEEN THE IMPORTED AND
SUBSTITUTED MERCHANDISE (I.E., SIZE, COLOR, GRADE,
STYLE, TEXTURE, DESIGN, ODOR, COMPOSITION, CRITICAL
PRODUCT SPECIFICATIONS, PURITY, ETC.). IDENTIFY WHETHER
DOMESTICALLY PURCHASED SUBSTITUTED MERCHANDISE HAS BEEN
IMPORTED. IF THE COMPANY HAS MANY DIFFERENT EXPORTED
ARTICLES, A DESCRIPTION OF EACH MAJOR PRODUCT GROUP, AT
MINIMUM, MUST BE PROVIDED. IF NECESSARY, DESCRIPTIONS
OF ALL THE DIFFERENT EXPORTED ARTICLES MAY BE REQUIRED.
THIS MAY REQUIRE SEPARATE COMMERCIAL INTERCHANGEABILITY
DETERMINATIONS, AS DISCUSSED ON PAGE 8 OF THIS MEMO.
(5) THE PART/MODEL NUMBERS, ITEM NUMBERS, OR OTHER
IDENTIFICATION NUMBERS WITH DESCRIPTIONS FOR BOTH THE
IMPORTED AND SUBSTITUTED MERCHANDISE. IF IMPORT AND
EXPORT NUMBERS OF SUBSTITUTED PRODUCTS DIFFER, PROVIDE
AN EXPLANATION OF THE DIFFERENCE. IF IMPORT AND EXPORT
NUMBERS DIFFER, SUBMIT A LIST SHOWING THE CROSS-
REFERENCE BETWEEN THEM.
(6) A COMPLETE COPY OF ALL DOCUMENTATION PERTAINING TO THE
PURCHASE AND/OR SALE OF THE IMPORTED AND SUBSTITUTED
GOODS. COPIES OF IMPORT AND EXPORT INVOICES, PACKING
LISTS FOR THE MERCHANDISE TO BE SUBSTITUTED, AND
PURCHASE ORDERS FROM THE CLAIMANT TO THE FOREIGN
SUPPLIER AND FROM THE FOREIGN CUSTOMER TO THE CLAIMANT
MUST BE SUBMITTED. THESE DOCUMENTS SHOULD TRACE ONE
OR MORE COMMERCIALLY INTERCHANGEABLE PRODUCTS FROM
IMPORT TO EXPORT. THIS IS VERY IMPORTANT AS A RESULT OF
THE TEXPORT CASE, AND ALLOWS CUSTOMS TO VERIFY THAT
DOUBLE SUBSTITUTION HAS NOT TAKEN PLACE.
NOTE: THE INVOICE USUALLY IS ONLY ONE OF SEVERAL
DOCUMENTS THAT COMPRISE THE PURCHASE AND/OR SALE
TRANSACTION, AND WHEN CONSIDERED ALONE MAY GIVE AN
INCOMPLETE DESCRIPTION OF THE TRANSACTION. THE
APPLICANT SHOULD STATE, IN WRITING, THAT THE DOCUMENTS
SUBMITTED COMPRISE THE COMPLETE SET OF THE APPLICANT'S
RECORD OF THE TRANSACTION.
(7) DOCUMENTATION THAT SUPPORTS COMMERCIAL INTERCHANGEABILITY
INCLUDE TECHNICAL BULLETINS, LITERATURE, LAB REPORTS,
SPECIFICATIONS, GOVERNMENT OR RECOGNIZED INDUSTRY
STANDARDS (ASTM, AISI, ETC.), OR MERCHANDISE CATALOGUES
ON THE IMORTED AND SUBSTITUTED MERCHANDISE SHOULD BE
SUBMITTED, IF AVAILABLE. THIS LITERATURE SHOULD DISCUSS
THE USES, GRADES, ETC., AND WILL HELP TO ESTABLISH
COMMERCIAL INTERCHANGEABILITY.
(8) THE LOCATION OF RECORDS WHICH INCLUDE INVENTORY,
IMPORT AND EXPORT DOCUMENTS MUST BE PROVIDED.
(9) A COMPANY CONTACT (NAME, TITLE, PHONE NUMBER) MUST BE
PROVIDED IN THE EVENT THAT FURTHER INFORMATION IS
REQUIRED BY CUSTOMS, AND TO ENABLE THE DRAWBACK OFFICE
TO NOTIFY THE COMPANY OF APPROVAL OR DENIAL OF THE
REQUEST.
(10) EXPORT COUNTRIES OF DESTINATION.
(11) THE HARMONIZED TARIFF CLASSIFICATION NUMBER OF THE
IMPORTED AND SUBSTITUTED MERCHANDISE. PROVIDE THE IMPORT
OF THE IMPORTED MERCHANDISE AND THE IMPORT/DOMESTIC VALUE
SUBSTITUTED MERCHANDISE.
NOTE: REQUESTS FOR COMMERCIAL INTERCHANGEABILITY SHOULD BE FILED AT
THE DRAWBACK OFFICE WHERE DRAWBACK CLAIMS WILL BE FILED.
CUSTOMS ACTION
DETERMINATIONS OF COMMERCIAL INTERCHANGEABILITY SHOULD BE MADE AS
EXPEDITIOUSLY AS POSSIBLE. UNLIKE WAIVER OF PRIOR NOTICE AND
ACCELERATED PAYMENT, THERE IS NOT A 90-DAY TIME FRAME FOR ACTION BY
CUSTOMS MANDATED IN THE NEW REGULATIONS. THIS IS BECAUSE FURTHER
ACTION ON COMMERCIAL INTERCHANGEABILITY REQUESTS IS SOMETIMES
REQUIRED BY FIELD LABORATORIES OR OR&R AND A 90-DAY TIME FRAME CANNOT
ALWAYS BE MET.
IF IT IS DETERMINED BY THE CUSTOMS LABORATORY OR OTHER CUSTOMS
OFFICIALS THAT SAMPLES OR TECHNICAL INFORMATION OR DATA PERTAINING
TO THE IMPORTED AND EXPORTED MERCHANDISE ARE NECESSARY IN ORDER TO
MAKE A DETERMINATION OF COMMERCIAL INTERCHANGEABILITY, THE CLAIMANT
SHOULD BE NOTIFIED OF THIS IMMEDIATELY, IN WRITING.
FOR MERCHANDISE THAT REQUIRES LABORATORY EXAMINATION, DRAWBACK
CENTERS WILL SUBMIT SAMPLES, IF AVAILABLE, ALONG WITH ALL INFORMATION
SUBMITTED BY THE CLAIMANT TO THEIR SERVICING FIELD LABORATORY.
LABORATORY WILL RENDER AN OPINION TO THE DRAWBACK CENTER AS TO WHETHER
THE MERCHANDISE IS INTERCHANGEABLE, WITH A NON-TECHNICAL EXPLANATION
OF THE BASIS FOR THE OPINION, WITHIN 45 DAYS OF RECEIVING THE
REQUEST.
IF ADDITIONAL INFORMATION IS NEEDED FROM THE CLAIMANT FOR LABORATORY
ANALYSIS, THE CLAIMANT SHOULD BE NOTIFIED IMMEDIATELY, IN WRITING.
PLEASE NOTE THAT ANY DETERMINATION REGARDING COMMERCIAL
INTERCHANGEABILITY IS ONLY BINDING IF IT IS MADE BY THE OFFICE
REGULATIONS AND RULINGS.
IF THERE IS A FAILURE TO PROVIDE ANY OF THE REQUIRED INFORMATION
AFTER BEING GIVEN AN OPPORTUNITY TO PROVIDE THE MISSING INFORMATION,
A LETTER STATING THAT NO ACTION WILL BE TAKEN UNTIL THE DEFICIENCY IS
CORRECTED WILL BE ISSUED.
IF THERE IS ANY DOUBT AS TO WHETHER THE IMPORTED MERCHANDISE TO BE
SUBSTITUTED IS COMMERCIALLY INTERCHANGEABLE, FIELD OFFICES SHOULD
SUBMIT THE FOLLOWING TO OR&R:
(1) A COPY OF ALL INFORMATION SUBMITTED BY THE CLAIMANT.
(2) A WRITTEN OPINION FROM THE DRAWBACK OFFICE AS TO WHETHER
THE MERCHANDISE IS COMMERCIALLY INTERCHANGEABLE,
INCLUDING ISSUES OR CONCERNS PREVENTING THE DRAWBACK
OFFICE FROM MAKING A PREDETERMINATION.
(3) A LABORATORY REPORT OR TECHNICAL OPINION FROM THE
SERVICING FIELD LABORATORY OR AN OPINION FROM THE FIELD
IMPORT SPECIALIST AND/OR NATIONAL IMPORT SPECIALIST, IF
APPLICABLE.
APPROVALS/DENIALS/APPEALS
IF IT IS DETERMINED THAT THE DESIGNATED AND SUBSTITUTED MERCHANDISE
ARE COMMERCIALLY INTERCHANGEABLE, AN APPROVAL LETTER WILL BE ISSUED
FOR ALL PREDETERMINATIONS DECIDED IN THE DRAWBACK CENTER (SEE
ATTACHMENT A FOR A SAMPLE APPROVAL LETTER). A COPY OF THE APPROVAL
LETTER SHOULD BE SUBMITTED WITH EACH CORRESPONDING CLAIM. THIS
ELIMINATES THE NEED FOR THE CLAIMANT TO PROVIDE SPECIFICATIONS WITH
EACH CLAIM.
THE PURPOSE OF THE NON-BINDING PREDETERMINATION LETTERS IS FOR
ADMINISTRATIVE EFFICIENCY WHEN:
1. THE APPLICANT STATES THAT IT WILL BE EXPORTING THE SAME
MERCHANDISE ON A REPETITIVE BASIS, AND
2. THE APPLICANT AND THE FIELD OFFICE DETERMINE THAT A NON-
BINDING LETTER WILL SUFFICE.
IF THE REQUEST IS DENIED, A LETTER TO THAT EFFECT MUST BE SENT TO THE
CLAIMANT. REVOCATIONS OF A COMMERCIAL INTERCHANGEABILITY APPROVAL
MAY BE NECESSARY IF DISCREPANCIES ARE FOUND DURING AN AUDIT, A DRAWBACK
COMPLIANCE VISIT, OR IF THE DRAWBACK CENTER RECEIVES INFORMATION
SUBSEQUENT TO APPROVAL THAT THE MERCHANDISE IS NOT COMMERCIALLY
INTERCHANGEABLE.
IF REQUESTS ARE DENIED OR APPROVALS ARE REVOKED, THE OFFICE OF FIELD
OPERATIONS, TRADE COMPLIANCE, DRAWBACK BRANCH SHOULD BE NOTIFIED,
IN WRITING, SPECIFYING THE REASONS FOR DENIAL OR REVOCATION. ALL
DRAWBACK CENTERS WILL BE NOTIFIED OF REVOCATIONS OR DENIALS BY
HEADQUARTERS.
CLAIMANTS MAY APPEAL DECISIONS OF THE DRAWBACK CENTERS TO THE OFFICE
OF REGULATIONS AND RULINGS IN HEADQUARTERS BY NOTIFYING THE DRAWBACK
CENTER WHERE THE ORIGINAL DETERMINATION WAS MADE, IN WRITING, THAT AN
APPEAL IS REQUESTED. DRAWBACK CENTERS RECEIVING REQUESTS FOR APPEAL
SHOULD FORWARD EACH REQUEST AS A REQUEST FOR INTERNAL ADVICE ALONG
WITH ALL RELATED INFORMATION TO THE BRANCH CHIEF, DUTY AND REFUND
DETERMINATION BRANCH, OFFICE OF REGULATIONS AND RULINGS, U.S.
CUSTOMS, 1300 PENNSYLVANIA AVENUE NW., WASHINGTON, D.C.
RESPONSIBILITIES:
TO ADDRESS REVENUE AND COMPLIANCE REQUIREMENTS OF THE CHIEF FINANCIAL
OFFICERS ACT AS WELL AS TO ENSURE NATIONAL UNIFORMITY IN DRAWBACK
PROCESSING, IT IS THE RESPONSIBILITY OF ALL DRAWBACK CENTERS TO
FOLLOW THE PROCEDURES SET FORTH IN THE REGULATIONS AND OUTLINED IN
THIS ISSUANCE.
NON-BINDING DETERMINATION LETTERS MAY BE DISTRIBUTED BY THE ISSUING
DRAWBACK OFFICE TO ALL OTHER DRAWBACK OFFICES, WHICH MAY USE THOSE
LETTERS TO COVER CLAIMS INVOLVING THE SAME MERCHANDISE DESCRIBED IN
THE LETTER. HOWEVER, THE LETTERS ARE NOT BINDING ON THE CUSTOMS
SERVICE, AND MAY BE REVERSED BY EITHER THE DRAWBACK OFFICE OR THE
OFFICE OF REGULATIONS AND RULINGS.
IF THERE IS ANY DOUBT IN THE DRAWBACK OFFICE AS TO WHETHER THE
IMPORTED MERCHANDISE AND THE MERCHANDISE TO BE SUBSTITUTED IS
INTERCHANGEABLE FOR COMMERCIAL PURPOSES, OR WHETHER A QUESTIONABLE
19 U.S.C. 1313(S) RELATIONSHIP EXISTS, A COMMERCIAL INTERCHANGEABILITY
DETERMINATION WILL BE MADE BY OR&R. CLAIMANTS MAY ALSO REQUESTA
BINDING RULING FROM OR&R DIRECTLY; HOWEVER, IT IS RECOMMENDED THAT
DRAWBACK CLAIMANTS ALSO FORWARD A COURTESY COPY OF BINDING RULING
REQUESTS TO THE APPROPRIATE DRAWBACK OFFICE WHERE FUTURE CLAIMS WILL
BE FILED.
IT SHOULD BE NOTED THAT CLAIMANTS MUST REQUEST SEPARATE COMMERCIAL
INTERCHANGEABILITY DETERMINATIONS FOR EACH INDIVIDUAL PRODUCT OR
CATEGORY OF PRODUCTS ON THEIR DRAWBACK CLAIMS.
SHOULD YOU HAVE ANY QUESTIONS REGARDING THESE PROCEDURES, PLEASE
CONTACT MR. AL MORAWSKI, CHIEF, DRAWBACK, HQ, AT (202) 927-1082,
MS. LYNN FALLIK, DRAWBACK, HQ, AT (202) 927-1082, OR MS. MARYANNE
CARNEY, CHIEF, DRAWBACK & RECORDS BRANCH, NEW YORK, AT
(212) 466-4575.
ATTACHMENT A
JOE DOE
NAME OF COMPANY
ADDRESS
CITY, STATE, ZIP
DEAR (SALUTATION):
THIS IS IN RESPONSE TO YOUR LETTER, DATED (DATE OF LETTER), REQUESTING
PERMISSION TO FILE CLAIMS UNDER SUBSTITUTION UNUSED MERCHANDISE
DRAWBACK INVOLVING REPETITIVE SHIPMENTS OF THE MERCHANDISE DESCRIBED
IN YOUR LETTER.
THE ARTICLES DESCRIBED APPEAR TO BE COMMERCIALYL INTERCHANGEABLE.
CONSEQUENTLY, PERMISSION IS GRANTED FOR THE FILING OF DRAWBACK CLAIMS
INVOLVING (IDENTIFY SPECIFIC MERCHANDISE FOR WHICH COMMERCIAL
INTERCHANGEABILITY APPROVAL IS BEING REQUESTED) IN ACCORDANCE WITH
TITLE 19, UNITED STATES CODE 1313(J), (S), AND (T), AND PART 191
OF THE CUSTOMS REGULATIONS, REVISED APRIL 6, 1998. NOTE THAT CLAIMS
FOR SUBSTITUTION UNUSED MERCHANDISE DRAWBACK MAY NOT INCLUDE EXPORTS
TO CANADA OR MEXICO.
PLEASE BE AWARE THAT, SHOULD THE NEED FOR A REVIEW OF COMMERCIAL
INTERCHANGEABILITY ARISE, WE RESERVE THE RIGHT TO EXAMINE FUTURE
EXPORTS OR REQUEST SAMPLES OF ITEMS.
THIS LETTER IS NOT BINDING ON THE CUSTOMS SERVICE AND MAY BE REVERSED
BY THIS OFFICE OR THE OFFICE OF REGULATIONS AND RULINGS (OR&R) IN
HEADQUARTERS. IF THERE IS ANY DOUBT, AT ANY TIME, AS TO WHETHER
THE IMPORTED AND SUBSTITUTED MERCHANDISE ARE COMPLETELY INTER-
CHANGEABLE FOR COMMERCIAL PURPOSES, THIS AUTHORIZATION MAY BE
REVIEWED AND, IF APPROPRIATE, REVOKED. THE PURPOSE OF THIS
PREDETERMINATION IS TO AVOID REPETITIVE SUBMISSIONS OF EVIDENCE
WITH RESPECT TO COMMERCIAL INTERCHANGEABILITY OF THE COVERED
MERCHANDISE WITH EACH CLAIM. IT IS YOUR RESPONSIBILITY TO NOTIFY
CUSTOMS IF THE MERCHANDISE OR EVIDENCE CHANGES.
ALL DRAWBACK CLAIMS FILED USING SUBSTITUTION UNUSED MERCHANDISE
DRAWBACK MUST INCLUDE A CF7551 SHOWING AN ENTRY TYPE CODE OF 45
IN BLOCK 2. A COPY OF THIS LETTER SHOULD BE ATTACHED TO EACH CLAIM
INVOLVING THE SUBSTITUTION OF UNUSED MERCHANDISE.
SHOULD YOU REQUIRE ADDITIONAL INFORMATION REGARDING THIS PROCEDURE,
PLEASE CONTACT THE DRAWBACK BRANCH AT (PHONE NUMBER).
SINCERELY,
(NAME)
(TITLE AND DRAWBACK OFFICE)
\S\ ANNE K. LOMBARDI, FOR
ROBERT S. TROTTER