As a result of two court decisions, importers possess the potential for obtaining duty refunds and duty savings in their purchases from trading companies which do not actually manufacture the underlying merchandise. These decisions reversed Customs’ longstanding position concerning back-to-back sales. As a result of two court decisions, importers possess the potential for obtaining duty refunds and duty savings in their purchases from trading companies which do not actually manufacture the underlying merchandise. These decisions reversed Customs’ longstanding position concerning back-to-back sales.