Why it Matters
A 169-year-old customs specialist is making its Washington debut. Comstock & Holt Inc., which helps companies recover duties on exported goods, hired Smith-Free Group LLC in September. The move signals growing concern about congressional activity on tariffs and trade policy.
By the Numbers
- Lobbying team: Five lobbyists from Smith-Free Group will handle the account.
- Spending: This marks Comstock & Holt’s first federal lobbying registration.
- Experience: The team includes Michael P. Mullen, who has lobbied for FedEx Corp. and Nike Inc. on trade issues. Jeffrey Maxwell Becker previously worked on import duties for Quince. Michael A. Gaffin has experience with duty drawback issues for tobacco companies.
Broader Context
Congress is actively considering major changes to customs and trade policy. Multiple bills addressing duty drawback procedures are moving through committees. The Trump administration’s trade agenda has prompted increased congressional oversight of customs operations. Recent hearings have focused on trade enforcement and negotiation priorities.
The Agenda
Comstock & Holt will lobby on “issues pertaining to duty drawback.” The registration covers trade, tariffs, and taxation matters. Duty drawback allows companies to recover duties on imported materials later exported as finished goods.
Competitive Landscape
Other duty drawback players are already lobbying heavily. Charter Brokerage LLC, a direct competitor, has retained multiple lobbying firms. The spirits industry, including Brown-Forman Corporation and Pernod Ricard USA, is pushing for the Duty Drawback Clarification Act. Tobacco companies like Altria Client Services are also active on these issues.
Between The Lines
Congress is considering several bills that could reshape duty drawback. The H.R.3028 – Duty Drawback Clarification Act would standardize whiskey tariff treatment. Rep. Morgan McGarvey and Rep. Steve Womack are championing the legislation. The Import Security and Fairness Act proposes changes to low-value import thresholds. Sen. Ted Budd has highlighted duty drawback protections for tobacco farmers. Recent hearings have examined the Trump Administration’s 2025 Trade Policy Agenda and U.S. Customs and Border Protection oversight.
The Bottom Line
Comstock & Holt’s lobbying debut reflects the heightened importance of duty drawback amid congressional trade policy debates. The company is positioning itself to influence legislation that directly affects its core business model.
All data used in this article came from Legis1. Request a demo to learn more!