By Bruce Hanson, Drawback Administrator
Amway Corporation
(Note: In 2000, Mr. Hanson conducted an analysis of Drawback.Net and wrote the following article highlighting the features that were of particular value to Amway Corporation. Mr. Hanson's bio follows the article.)
Amway recently completed a drawback compliance visit conducted by the US Customs drawback office where Amway files its drawback entries. As you may be aware, each drawback office has its own method of conducting their "review".
The US Customs drawback office Amway deals with was very concerned regarding the imports coded "used by" for manufacturing drawback entries. The general explanation was to notify them that once the merchandise is received it could possible enter the manufacturing process on several different days. A simple written explanation of this scenario was conveyed to the liquidator and he was satisfied with Amway's response to their inquiry. Amway took advantage of an opportunity to show the liquidator how imports are designated using Drawback.Net. Hanson says this fact alone "dazzled" the liquidator. Amway was able to prepare various schedules explaining the whole designation process (i.e. by part number and import entry number); detailed all the way down to which drawback claims the import entry number appeared in.
As an example, Amway was able to take an imported part number that appeared in the export that Amway was tracing by using the "Imports Designated History" function. They outlined each drawback claim where a particular import part number from a particular import entry was designated by drawback entry number. By running this report, you can also create backup data for filing drawback claims (i.e. FIFO, Low to High, etc.). In addition, these reports will assist you in import records retention; for example, once the import entry is fully exhausted (three years after payment) you would no longer need to keep the import entry. This feature within Drawback.Net can provide backup and documentation for many of the questions that may arise during a compliance visit.
Another useful feature within Drawback.Net is the Exports Claimed History function. Amway was able to use this feature to create a report illustrating part numbers claimed by finished good number and by invoice number (your unique identifier). Once again, the system was able to provide a summary of this activity which also enables the drawback user to inform upper management of "high return" items.
In conclusion, Hanson says, "Review your company records that support drawback claims and use the additional Drawback.Net features. You'll be glad you did."
Bruce Hanson started his Customs career as an auditor for the U.S. Customs Service for four years specializing in U.S./Canada Free Trade, NAFTA and valuation audits. Bruce then began working as a Customs Consultant for one of the Big Five accounting firms (Deloitte & Touche, LLP) specializing in Compliance Assessment Tests, NAFTA compliance, valuation and Drawback consulting. Upon joining the staff at Amway, Bruce succeeded in reorganizing their drawback department and captured more than $2.5 million drawback refunds in just his first year. Bruce holds a Bachelor's of Science degree in Accounting from Southern Illinois University.
Back to top
