Rule by rule:
Customs business (19 CFR 111.1). Preparing drawback claims for others is customs business. The agent drafts; your licensed staff decide each line and file.
CBP has said "a tool does not constitute a 'person'."
- Direct power of attorney (H350722). The POA must come directly from the importer or drawback claimant; a platform "may not act as an intermediary." Ours never collects or relays one.
- Confidentiality (111.24). You share client records only with the client's written consent, which we collect at onboarding.
- Supervision (111.28). The portal logs each approval, reviewer, training record and reject rate, so you can show responsible supervision.
- Fee sharing (111.36(b)). No customs-business fees reach unlicensed partners. Brokers pay us software fees, not a share of their fees.
- Breach reporting (111.21). Our incident notices are sized to your 72-hour report to CBP.
Not legal advice.
- 19 CFR 111.1, 111.21, 111.24, 111.28, 111.36[1][2][3][4][5]
- CBP ruling H350722, Jan 16, 2026[6]
- Is drawback partnering legal for customs brokers?
Written by the NexQloud Drawback team from the primary sources linked on this page.
Not legal advice. NexQloud Drawback is not a government agency.
NexQloud Drawback is software used by licensed customs brokers.
