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April 2025, question 25

Modernized Drawback · Drawback

AZ-DZ Audio, Inc. (AZ-DZ) manufactures stage monitor loudspeakers (monitors) in Arizona from a mix of foreign and domestic components. Three years ago, AZ-DZ made a special export edition of its “Goes to Eleven” monitor for customers outside the U.S. That same year, AZ-DZ imported special gold cables from South Korea to be used in the Goes to Eleven monitors. AZ-DZ did not use all of the imported cables to make monitors and exported its excess stock back to the supplier last year. AZ-DZ now wants to claim unused merchandise drawback under 19 USC 1313(j) for duties paid on the unused cables. AZ-DZ never provided prior notice of intent to export or destroy merchandise to CBP as required by 19 CFR 190.35. In order to claim unused merchandise drawback despite its failure to comply with 19 CFR 190.35, AZ-DZ files an application with CBP’s Detroit Drawback office pursuant to the CBP regulations. Which of the following information is AZ-DZ NOT required to provide in their application?

  1. The port(s) of exportation of the cables
  2. The relationship between the parties involved in the import and export transactions
  3. The export period covered by the application
  4. The country or countries to which the unused cables were exported
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CBP's answer: D. D: The country or countries to which the unused cables were exported

Section 190.36(a)(1)(i) lists what the application must contain, including the port(s) of exportation, the relationship between the parties and the export period covered. It does not list the countries of export, so D is the item not required.

The port(s) of exportation 19 CFR 190.36(a)(1)(i)(H)
The relationship between the parties involved in the import and export transactions 19 CFR 190.36(a)(1)(i)(J)
Export period covered by this application 19 CFR 190.36(a)(1)(i)(C)

Search for: Failure to file Notice of Intent to Export

CBP's key cites: 19 CFR 190.35; 19 CFR 190.36

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).