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April 2025, question 22

Modernized Drawback · Drawback

X-Rocs, Inc. (X-Rocs) imports multifunction digital office machines (copiers) with copy, print, fax, and scan functions to the U.S. from Korea. X-Rocs has a valid limited power of attorney (POA) with Expeditious Customs Brokers, LLC (Expeditious), limited to entering imported merchandise for consumption. Four years after importation, if the copiers have not sold in the U.S., X-Rocs exports the copiers to India. X-Rocs has a valid limited POA with Trade Experts Customs Brokers (TradeEx) for its drawback program. X-Rocs’ Vice President has signed a POA granting X-Rocs’ Trade Compliance Manager, who is not a licensed customs broker, the power to sign contracts and business documents on behalf of X-Rocs. A broker at TradeEx executed a POA with an unlicensed employee to sign customs business documents on behalf of TradeEx. Of the list below, who does NOT have the authority to sign drawback entries submitted to CBP on behalf of X-Rocs?

  1. The Vice-President of X-Rocs
  2. An employee of Expeditious
  3. The Trade Compliance Manager with X-Rocs
  4. The unlicensed employee of TradeEx
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CBP's answer: B. B: An employee of Expeditious

Section 190.6 says drawback entries may be signed only by listed persons: an officer such as the vice president, an employee with a power of attorney, or a licensed broker with a POA to sign the drawback document. The Expeditious POA is limited to entering merchandise for consumption, so its employee has no authority to sign drawback entries (B). The Vice President and the Trade Compliance Manager (who holds a POA from X-Rocs) qualify under 190.6(a)(1) and (a)(4), and TradeEx holds the drawback POA, so CBP treats D as authorized.

Any employee of the business entity with a power of attorney 19 CFR 190.6(a)(4)
A licensed customs broker with a power of attorney to sign the applicable drawback document. 19 CFR 190.6(a)(6)

Search for: signed or electronically certified only by one of the following

CBP's key cites: 19 CFR 141.0a(f); 19 CFR 190.2; 19 CFR 190.6(a)

Question and key from CBP's April 2025 exam and answer key. The walk-through is ours; quotes are from the pinned editions in the reference viewer (HTSUS 2026 Basic, 19 CFR 2025 edition).