April 2025 — Question 23

WeHeartGoats, Inc. (WeHeartGoats), a goat soap manufacturer and exporter, imports burlap, sewing thread, and string in bulk from which WeHeartGoats makes burlap drawstring bags that hold individual bars of soap. WeHeartGoats sews its own drawstring bags from the imported bulk burlap and string. The soap is made using goat milk and other ingredients. None of the ingredients to create the soap are imported. Because the burlap bags breathe, they are better packaging than paper or plastic for the soap bars. WeHeartGoats intends to claim drawback on the burlap and string that it manufactures into the drawstring bags upon the exportation of the soap-filled bags. Which the following statements is TRUE?

• AThe WeHeartGoats’ drawstring bags, although wholly manufactured with imported materials, are ineligible for drawback because the bags are packaging for U.S. origin soap, and packaging that contains articles or merchandise not eligible for drawback is also not eligible for drawback.
• BIf WeHeartGoats receives acknowledgement of its letter of notification of intent to operate under a general manufacturing ruling from the drawback officer where the drawback entries are to be filed, the letter of notification will remain in effect for five years from the date of the first drawback claim filed in accordance with the letter of notification.
• CIf WeHeartGoats determines that a general manufacturing drawback ruling can be followed without variation, concurrent with or prior to filing a drawback claim, WeHeartGoats will file a letter of notification of intent to operate under a general manufacturing drawback ruling with the drawback officer where the drawback entries are to be filed.✓ CBP's answer
• DIf, after receiving acknowledgement of its letter of notification of intent to operate under a general manufacturing drawback ruling from the drawback officer where the drawback entries are to be filed, WeHeartGoats decides to change its name to WeHeartGoats.US, Inc., the company must must file a supplemental application. The supplemental application would be filed with CBP Headquarters, Office of Trade, Regulations and Rulings, Entry Process and Duty Refunds Branch (CBP Headquarters), for authorization to continue operating under its existing ruling.