Packaging Drawback: Recovering Duty on Imported Packaging Materials

Imported packaging, such as bottles, jars, compacts, tubes and boxes, qualifies for drawback when it is used to package goods that are exported or destroyed. The statute addresses packaging material directly in 19 U.S.C. 1313(q). For brands that import packaging and fill it in the U.S., packaging drawback can be a meaningful refund that most of them never claim.

Who uses packaging drawback

• Beauty and personal care brands that import compacts, bottles and applicators and fill them in the U.S.
• Food and beverage companies that import containers.
• Any manufacturer that imports packaging and exports finished, packaged goods.

How it works

The duty paid on the imported packaging is tied to the exported product it holds. The claim follows the same rules as the underlying drawback type, so records have to show which packaging went into which exported goods. Substitution rules can apply where packaging is interchangeable.

The records

• Import entries for the packaging, with HTS numbers and duty paid.
• Bills of materials linking each packaging component to each finished SKU.
• Production and fill records.
• Export records for the finished goods.

Frequently asked questions

Do I need a manufacturing ruling? If the packaging is part of a manufacturing process, the claim generally runs under manufacturing drawback and a ruling applies. See the manufacturing drawback guide.

Can I claim packaging and contents together? Yes, when both were imported and duty was paid on both.

A real example

Fiera Cosmetics makes beauty products in the U.S. from imported components and sells them globally. Its packaging-based claims cover and match more than 750,000 units of products and packaging items. See the Fiera case study.

How Caspian handles packaging drawback

Caspian maps your bills of materials to your packaging imports and files the claim. See our duty drawback services.

Works Cited:

• 19 U.S.C. 1313, Drawback and refunds
• 19 CFR Part 190, Modernized drawback