Lewis Leibowitz, NAFTZ Chairman
Scott Wienke, NAFTZ Vice Chairman
Trey Boring, NAFTZ Board of Directors
January 2012
Orlando, Florida
©National Association of Foreign Trade Zones All Rights Reserved
FOREIGN TRADE ZONES—
DEFINITIONS, PURPOSES, LEGAL
STATUS
©National Association of Foreign Trade Zones All Rights Reserved
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Foreign Trade Zones (FTZs)
Secure areas located in or ―adjacent to‖ a
Customs Port of Entry
Legally outside the US Customs territory
Any merchandise not prohibited by law may be
admitted to an FTZ
Merchandise in an FTZ may be
Assembled, exhibited, cleaned, manipulated,
manufactured, mixed, processed, relabeled,
repackaged, repaired, salvaged, sampled, stored,
tested, displayed, & destroyed
Retail trade is not allowed
©National Association of Foreign Trade Zones All Rights Reserved
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Purposes of the FTZ Program
Many countries have free zones to expedite and encourage foreign commerce Entrêpots
Special Economic Zones
Export Processing Zones
Free Zones
Maquiladoras
Purpose of the U.S. FTZ Act of 1934 was to ―expedite and encourage foreign commerce‖ Part of effort to revitalize trade after Smoot Hawley Act of 1930
and the Great Depression
Create Jobs and Investment in the US that could otherwise take place overseas
©National Association of Foreign Trade Zones All Rights Reserved
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Key Developments
Milestones of FTZ Program 1934—signed into law 1950—manufacturing, exhibition, zone restricted status
permitted in FTZs, subject to FTZ Board approval
1977—first auto assembly plant with FTZ status
1980—domestic value added and materials ruled NOT part of dutiable value
1986—introduction of audit-inspection system for FTZs
1987—exemption from annual and activation fees for FTZs
1996—production equipment admitted to zones without payment of duty
2000—weekly entry for all zones
©National Association of Foreign Trade Zones All Rights Reserved
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National Benefits of FTZ Program
US operations become more globally competitive More jobs in the US
More exports to global markets
National Export Initiative Only __ percent of US manufacturers export
National goal to double exports from 2009 to 2014
©National Association of Foreign Trade Zones All Rights Reserved
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What Does This Mean to Business?
‗Outside the Customs Territory‘ is the legal position that provides the benefits of the FTZ program
Goods in zones are considered to be part of international commerce, not domestic
It is only once goods leave the zone to enter the commerce of the US, that normal tariff and Customs regulations apply to those goods
©National Association of Foreign Trade Zones All Rights Reserved
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General-Purpose Zone
A site or facility that provides multiple users
with varying types of merchandise access to
the benefits of the FTZ Program
Original concept was a public warehouse
Evolved to include industrial parks or port
complex where sites/facilities are available
for use by multiple users
Serves as the sponsoring zone for any
subzone
©National Association of Foreign Trade Zones All Rights Reserved
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Subzone
Normally single-purpose, single user sites when the operations cannot feasibly be moved to, or accommodated in a general purpose zone
Frequently, an established manufacturing or large distribution operation
©National Association of Foreign Trade Zones All Rights Reserved
THE NAFTZ
©National Association of Foreign Trade Zones All Rights Reserved
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Meet the NAFTZ
The ―voice of the foreign trade zones program‖
Trade association of state and local government entities, public development organizations, private corporations, consultants and lawyers involved in the US FTZ program
Advocate for economic benefits to the economy from FTZs
Educate participants, regulators and opinion leaders about the FTZ program
©National Association of Foreign Trade Zones All Rights Reserved
FEDERAL GOVERNMENT IN THE FTZ
PROGRAM
©National Association of Foreign Trade Zones All Rights Reserved
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FTZs and Customs
FTZs are one of many Customs procedures to
import and export merchandise
Federal regulation is a feature of all these
processes
©National Association of Foreign Trade Zones All Rights Reserved
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FTZ Board
The FTZ Board is composed of the Secretary of
Commerce and Secretary of Treasury
Alternates of each Secretary are empowered to perform
many functions of the FTZ Board
FTZ Board is authorized to consider making grants to
establish, expand, operate, and maintain FTZs in all
forms
Prescribes rules and regulations to establish and operate
zones
Requires submission of reports regarding information
related to zone operations
Prepares annual report of FTZ activity to Congress
©National Association of Foreign Trade Zones All Rights Reserved
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FTZ Board Alternates
Alternates may perform duties of the members of the
Board
Assistant Secretary of Commerce for Import Administration
Deputy Assistant Secretary of Treasury for Tax, Trade and Tariff
Policy
©National Association of Foreign Trade Zones All Rights Reserved
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FTZ Board Executive Secretary
Director of Foreign Trade Zones Staff
Represents Board in administrative, regulatory,
and operational matters
Initiates recommendations to the Board for
overall administration of the FTZA
Approves boundary modifications with
concurrence of appropriate Port Director
Accepts rate schedules and determines their
sufficiency under the regulations
©National Association of Foreign Trade Zones All Rights Reserved
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U.S. Customs and Border Protection
(CBP)
Regulation of imports into U.S.
Regulates merchandise moving into and out of
FTZs
Collects Customs duties and fees
Ensures adherence to laws and regulations
governing imported and exported merchandise
©National Association of Foreign Trade Zones All Rights Reserved
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CBP Port Director
Oversees zone as local FTZ Board representative
Reviews port policy and comments on applications and activations of zones
Advises Zone Operator on questions presented
Determines amount and conditions of FTZ Operator‘s Bond
©National Association of Foreign Trade Zones All Rights Reserved
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Grantee
A public or private ―corporation‖ (frequently
port authorities, state/local economic
development agency)
Applies for grants of authority
May operate zone sites or delegate
responsibility by contract to another party
©National Association of Foreign Trade Zones All Rights Reserved
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Operator
The entity that deals directly with CBP on day
to day matters
Operator is responsible for CBP Compliance
within the zone
May be grantee or another corporation
A zone project may have more than one
operator
©National Association of Foreign Trade Zones All Rights Reserved
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User
Persons or firms using a zone or subzone for
storage, handling, or manufacturing
Users receive benefits of participation in the
FTZ Program
Users may also be operators
©National Association of Foreign Trade Zones All Rights Reserved
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Customs Broker
May be used to transact Customs business
on behalf of an operator or user
Importer always retains right to transact
business on its own behalf
©National Association of Foreign Trade Zones All Rights Reserved
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FTZ Administrator
Grantee may contract with another company
responsibilities for a zone project to another
company (e.g., oversight of users and operators,
marketing of zone)
May be a source of technical expertise on CBP
and FTZ Board issues
FTZ Administrator not recognized in FTZ Board
regulations
Zone Administrator does not relieve Grantee of
responsibilities to FTZ Board
©National Association of Foreign Trade Zones All Rights Reserved
ZONE STATUS
©National Association of Foreign Trade Zones All Rights Reserved
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Purpose
A zone status is selected for merchandise at time of admission by the user
Indicated on admission (CBPF214 or e214)
Determines HTS classification and duty rate to be applied when merchandise is removed from the zone HTS classification of the merchandise as admitted to
the zone
HTS classification of the merchandise that is being removed from the zone
©National Association of Foreign Trade Zones All Rights Reserved
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Types of Zone Status
Privileged Foreign (PF) (19 CFR 146.41)
Non-Privileged Foreign (NPF) (19 CFR 146.42)
Domestic (D) (19 CFR 146.43)
Zone Restricted (ZR) (19 CFR 146.44)
©National Association of Foreign Trade Zones All Rights Reserved
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Privileged Foreign (PF)
Will be appraised and classified in condition of
merchandise at the time PF status is elected
PF status is binding no matter what occurs
within zone
Merchandise subject to antidumping or
countervailing duties must be admitted in PF
status
©National Association of Foreign Trade Zones All Rights Reserved
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Non-privileged Foreign
(NPF)
Will be appraised and classified based on the
condition of the merchandise at the time of entry
into the US commerce (removal from the zone)
Activity within zone can change HTS classification
prior to entry for consumption
FTZ Board may restrict ability of zone user to elect
non-privileged foreign status on ―public interest‖
grounds
©National Association of Foreign Trade Zones All Rights Reserved
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Non-privileged Foreign
(NPF)
Waste recovered from PF status merchandise is
assigned NPF status
Domestic merchandise which has lost its identity
will be assigned NPF status
NPF status may be changed to PF prior to any
manipulation or manufacture
©National Association of Foreign Trade Zones All Rights Reserved
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Domestic (D)
Growth, product, or manufacture of the US on
which all federal excise tax has been paid
Previously imported and entered into Customs
territory
All duty and tax paid
All fees paid
Domesticated
©National Association of Foreign Trade Zones All Rights Reserved
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Zone-Restricted (ZR)
Merchandise brought into a zone for the
purpose of exportation, destruction, or storage
May be brought into the zone from outside the US
May be brought into the zone from US Customs
territory
ZR status may be elected at any time
©National Association of Foreign Trade Zones All Rights Reserved
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Zone-Restricted (ZR)
May not be sent into Customs territory for
consumption unless the FTZ Board finds return
in the ―public interest‖
May not be manufactured in a zone
May be considered exported for purposes of
satisfying Customs or other Federal agency
laws (e.g., drawback)
©National Association of Foreign Trade Zones All Rights Reserved
ZONE BENEFITS
©National Association of Foreign Trade Zones All Rights Reserved
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Basic Financial Benefits
Duty deferral
Duty elimination on exports
Duty reduction (inverted tariff relief)
Duty Reduction on Scrap/Waste
Weekly entry
Local ad valorem tax exemption
Basic Premise - Import duties are not paid
until, and unless, the goods enter the
commerce of the United States
©National Association of Foreign Trade Zones All Rights Reserved
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Duty Deferral
Cash flow benefit Duty not paid until goods leave zone
Merchandise Processing Fee deferred until goods leave zone
Harbor Maintenance Fee is paid quarterly
Use of funds is retained by the importer as long as goods remain in the zone
Not a permanent source of savings
©National Association of Foreign Trade Zones All Rights Reserved
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Duty Deferral
May delay payment until closer to generation of
sales revenue
Example: Seasonal goods
May delay payment until a reduction or
elimination opportunity arises further down in the
supply chain
Example: Zone-to-zone transfers
©National Association of Foreign Trade Zones All Rights Reserved
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Calculating Deferral
Savings
• $ volume of imports ÷
• Inventory turns per year X
• Duty rate of product X
• Reduction of Borrowings
• Opportunity cost of capital =
• Example: [($50,000,000 ÷ 2) X 5%] x 6% = $75,000
• $50,000,000 ÷ 2 = $25,000,000
• $25,000,000 x 5% = $ 1,250,000
or
• $ 1,250,000 x 6% = $ 75,000
©National Association of Foreign Trade Zones All Rights Reserved
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Duty Elimination
US. Duty not paid on merchandise EXPORTED from the zone Merchandise never enters commerce of US, so no
duty is owed to the US Exception: Manufactured products exported to Canada or
Mexico under NAFTA (more on this later)
No merchandise processing fee liability on exported merchandise Exception: Manufactured products exported to Canada or
Mexico under NAFTA (more on this later)
More cost effective and flexible than other Customs procedures (e.g., drawback, bonded warehouse, TIB
©National Association of Foreign Trade Zones All Rights Reserved
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Duty Elimination/Reduction
U.S. Duty not paid or reduced on merchandise DESTROYED in the zone CBPF 216 or Customs Entry option
Merchandise destroyed and sent to landfill, incinerator, etc., has $0 value but $1 must be used for entries
Destruction must be complete with no residual value
Merchandise sold as scrap/recycled is classified under original, other, or scrap provision with original, reduced, or FREE duty rate Value is price received for scrap
©National Association of Foreign Trade Zones All Rights Reserved
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Duty Reduction
Duty paid may be based on:
Classification of merchandise as admitted
Classification of finished product removed from the
zone (can be duty rate of zero)
User determines based upon which is lower
Determined by status selected at admission
PF: Duty rate of the merchandise as admitted
NPF: Duty rate of finished product as entered
Also known as an ―irrational‖ or inverted tariff
©National Association of Foreign Trade Zones All Rights Reserved
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Calculating Duty-
Reduction Savings
• Duty rate of merchandise admitted to zone
(components, raw materials) 5%
• Duty rate of merchandise removed from zone
(manufactured product) 2%
• Example:
• $50,000,000 x 5% = $2,500,000
• $50,000,000 x 2% = $1,000,000
• Savings = $1,500,000
©National Association of Foreign Trade Zones All Rights Reserved
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WEEKLY ENTRY
Reduction of MPF and Brokerage
Merchandise Processing Fee: Calculated for each entry 0.3464% of entered value
(maximum $485 per entry)
Entries are not filed until merchandise leaves the FTZ for US Customs territory
A single entry can be filed for up to one week‘s shipments from a zone Estimated weekly entry (CF 3461)
Fewer entries save MPF, brokerage fees
©National Association of Foreign Trade Zones All Rights Reserved
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Ad Valorem Tax Exemption
FTZ Act Provision 19 U.S.C. §81o(e) –
merchandise in foreign status is exempt from
state and local personal property taxes
Some states expand on this exemption
Check applicable law in your state
©National Association of Foreign Trade Zones All Rights Reserved
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Other Benefits
Improved CBP compliance
Lower security and insurance costs
Shorter transit time using direct delivery
No time constraints on storage
Improved inventory control
Informed CBP officer
©National Association of Foreign Trade Zones All Rights Reserved
REGULATORY & STATUTORY
REQUIREMENTS
©National Association of Foreign Trade Zones All Rights Reserved
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FTZ Act (FTZA)
19 USC 81a - 81u
FTZ Act of 1934, as amended, established
application procedures
Section 81f requires description of the proposed
location, qualifications, financing, and operating
details
Section 81a(a)(5) authorizes the FTZ Board to
require other information
©National Association of Foreign Trade Zones All Rights Reserved
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FTZ Board Regulations
15 CFR Part 400
Revised FTZ Board regulations in effect 11/7/91
Adopted criteria for reviewing zone activity resulting in tariff
classification changes of imported merchandise
Proposed Regulations published on December 30, 2010
First major revision since 1991
Comment period expired in late June 2011
Awaiting issuance of final regulations in 2012
Some issues may have another round of comments on revised
proposals
NAFTZ provided comments in May and June 2011
©National Association of Foreign Trade Zones All Rights Reserved
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GP Zone Adjacency Requirement
15 CFR §400.21(b)(2) states that the adjacency
requirement will be satisfied if a general purpose
zone is located:
within 60 statute miles or
90 minutes driving time from the limits of a Port of Entry
CBP Port Director determines adjacency
©National Association of Foreign Trade Zones All Rights Reserved
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Subzone Adjacency Requirement
Subzones almost anywhere can satisfy
adjacency requirements
Proper CBP oversight can be accomplished with
physical and electronic means
Electronic records are maintained in a format
compatible with CBP requirements
Operator agrees to present merchandise for exam
upon request at a site selected by CBP and present
documents directly to CBP
©National Association of Foreign Trade Zones All Rights Reserved
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CBP Regulations
19 CFR Part 146 has CBP regulations specific to
FTZ operations
Other sections of CBP Regulations will also apply:
Entry requirements
Bond requirements
Valuation
Country of origin marking
Fines, Penalties, Forfeitures, Liquidated Damages
©National Association of Foreign Trade Zones All Rights Reserved
FTZ APPLICATION PROCESS
©National Association of Foreign Trade Zones All Rights Reserved
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Getting Started
Grantee Sponsorship
Zones are public utilities
FTZ Board only accepts applications from Grantees
Grantees may have overlapping service areas
Preferred Grantee is closest zone within the same
State as a proposed subzone
Alternative Site Framework may alter which Grantee is
appropriate
©National Association of Foreign Trade Zones All Rights Reserved
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Preparing the Application
Preliminary discussions with FTZ Board and
Customs
FTZ Board and Customs should be notified of
application prior to submission
Should minimize delays, complications, or conflicts
that could occur during the application process
Allows for a good head start into the activation
process
©National Association of Foreign Trade Zones All Rights Reserved
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Application Contents
FTZ Board has issued Application Guidelines
The Exhibits in the regulations are no longer followed
FTZ Board web site has specific questions and
formatting preferred for applications
Visit http://ia.ita.doc.gov/ftzpage/applications.html
for questions to be answered
©National Association of Foreign Trade Zones All Rights Reserved
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Transmittal Letter
Dated and signed by officer of grantee
Bear grantee organization seal
Contain grantee‘s FTZ number
Identify proposed user company
Brief summary of request
Explain economic and zone benefits for company
and local community
Request approval of application
©National Association of Foreign Trade Zones All Rights Reserved
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New GP or Expansion of
FTZ Project
Each Customs Port of Entry is entitled to at least one zone
Most Ports have a zone authorized
The application must come from a proposed Grantee, not individual companies
The zone project must be part of an overall economic plan for the region to attract and retain business
Local community support is essential
©National Association of Foreign Trade Zones All Rights Reserved
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GPZ Approval Process
Once the application is filed, the FTZ Board
evaluates the application considering the
following factors:
Does the port of entry area need additional general
purpose zone sites
Are proposed sites and facilities suitable
Is there local support in the community for the
proposed project
Is the proposed project in the public interest
©National Association of Foreign Trade Zones All Rights Reserved
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Subzone Application
A stand alone, single use site
The application must come from a public entity
(the grantee), not the individual companies
desiring zone benefits.
Provide significant public benefit in terms of
employment, exports, retention of manufacturing
jobs, US value added, foreign competition
©National Association of Foreign Trade Zones All Rights Reserved
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Manufacturing or
Processing
Manufacturing - substantial transformation of one item to another
Processing - change in tariff number within the zone
FTZ Board must approve request for manufacturing or processing under zone procedures in order to realize the zone benefits
Before initiating activity beyond authorized scope, written request must be made to Executive Secretary and approval received
©National Association of Foreign Trade Zones All Rights Reserved
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Subzone Application / Manufacturing
Authority
Effect on investment, employment
International competition
Trade policy impacts from zone status (threshold
criteria) Trade restrictions (quotas, high tariffs that could be reduced by
zone status)
AD/CVD issues
Potential opposition Domestic suppliers
Domestic competitors not benefiting from FTZ status
©National Association of Foreign Trade Zones All Rights Reserved
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Acceptance of Application
Executive Secretary will:
Formally docket the application, thereby initiating
proceeding or review
Assign a case docket number in cases requiring a
Board Order
Notify applicant of acceptance of application
Publish Federal Register notice requesting public
comment
©National Association of Foreign Trade Zones All Rights Reserved
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Hearings (15 CFR 400.51)
Hearings may be announced by the FTZ Board,
Alternates or Exec. Secretary Hearings may be requested by a private party
FTZ Board will publish notice in the Federal
Register of the date, time and location of any
hearing
©National Association of Foreign Trade Zones All Rights Reserved
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Examiner’s Report
Evaluation done by FTZ Board analysts
Report will evaluate economic factors
addressed in Exhibit 4
Comments (both pro and con) are requested
and must be responded to
Industry experts in government are consulted
Consideration of Customs comments
©National Association of Foreign Trade Zones All Rights Reserved
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Grant of Authority
Processing time 6 - 12 months
Opposition
Industry Issues
Previous application precedents
FTZ Board either issues or denies grant of
authority through a formal order of FTZ Board
FTZ Board Order specifies type of grant and any
grant restrictions
Reported in Federal Register
©National Association of Foreign Trade Zones All Rights Reserved
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Lapse of FTZ Authority
Grant of authority shall lapse within five years
from a Board order if a zone or subzone is not
activated within that time
©National Association of Foreign Trade Zones All Rights Reserved
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Minor Boundary
Modification
Designated acreage in approved zone site relinquishes status so equal acreage can receive it Acreage must be similar in usage
Request must be submitted by Grantee
Must be consistent with the zone plan approved by the FTS Board
Limited in size
Request is submitted to FTZ Board for approval by Executive Secretary
CBP concurrence letter submitted with request
Requires 30 day review process
©National Association of Foreign Trade Zones All Rights Reserved
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T/IM Applications
Temporary/Interim Manufacturing initiated in October 2004
Provides expedited and lower cost access to zone benefits for manufacturers located in existing FTZ sites
Companies can obtain temporary approval for inverted tariff relief (up to 2 years) within 75 days versus the standard 1 year
©National Association of Foreign Trade Zones All Rights Reserved
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T/IM Applications
Finished products/components must be similar to prior approvals
Temporary approval for up to two years, pending full manufacturing approval
Can apply for permanent manufacturing concurrently (even on same form)
©National Association of Foreign Trade Zones All Rights Reserved
ASF a ―framework‖ available to Grantees to
manage FTZ sites
Greater flexibility in FTZ site designation
A Grantee can apply to the FTZ Board to
―reorganize‖ under the ASF
Alternative Site Framework (ASF)
©National Association of Foreign Trade Zones All Rights Reserved
Many unused FTZ sites under traditional
framework
Too much potential responsibility for CBP locally
Too much responsibility for Grantee without actual
use
New sites may require significant waiting for new
users
Why ASF?
©National Association of Foreign Trade Zones All Rights Reserved
―Service Area‖ is the geographic area where grantee
intends to propose general-purpose FTZ sites
A ―Magnet‖ site is one selected by grantee based on
ability to attract multiple potential FTZ operators/users
A ―Usage-Driven‖ site is designated for a company
ready to pursue conducting FTZ activity
―Activation Limit‖ is cap on amount of space that can
simultaneously be in CBP ―activated‖ status (generally
2000 acres—no zone has ever hit the limit)
Terms and Concepts
©National Association of Foreign Trade Zones All Rights Reserved
Ongoing ―Sunset‖ tests remove unused sites.
Standard five-year sunset period for Magnet sites
Three-year sunset period for all Usage-Driven sites
Sunset deadline for each Magnet site extended for
additional five years based on the site‘s activation at any
time during the sunset period
ASF: Examples
©National Association of Foreign Trade Zones All Rights Reserved
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Applying for a Usage-Driven Site
Submitted by the grantee on behalf of a company
Information needed:
Site address/acreage
Company/activity
Right to use site
Map
Legal description
Concurrence from CBP
Timeline: within 30 days
©National Association of Foreign Trade Zones All Rights Reserved
The ASF can speed up companies access to the
competitive benefits of FTZs.
ASF dramatically reduces burden and increases flexibility
and predictability on designation of FTZ sites to meet
companies‘ needs in the region.
The Bottom Line:
©National Association of Foreign Trade Zones All Rights Reserved
FTZ ACTIVATION PROCESS
©National Association of Foreign Trade Zones All Rights Reserved
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Activation Process
Activation is the approval by the Port Director
and the grantee for the zone to begin operations
Activation request letter sent to Customs
includes
Blueprint of the approved areas showing the area to
be activated including all buildings, openings, inlets,
outlets, pipelines to tanks or storage of liquid
products
©National Association of Foreign Trade Zones All Rights Reserved
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Activation Requirements
Activation requirements and procedures
Written application
Blueprint of area to be activated
Gauge table (if appropriate)
Zone procedures manual
Background investigation of key employees
Approved security
FTZ Operator‘s Bond
Written concurrence from the grantee
©National Association of Foreign Trade Zones All Rights Reserved
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Initial Meeting with CBP
Gain an understanding of the zone project
Meet the people involved with the zone
Explain the Customs role, policies, and
procedures
©National Association of Foreign Trade Zones All Rights Reserved
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Initial Meeting With Customs
Conduct preliminary security check
Begin background checks
Begin procedures for establishing amount of
Operator‘s Bond
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Blueprint - Defining
Physical Area
Entire physical area approved in the grant can be activated
Portion of the area approved in the grant can be activated based on FTZ benefits sought
Production count point
Consideration of 5 day removal requirement
Any area where foreign goods admitted to the zone can be stored, processed, manufactured or shipped must be in the activated area
©National Association of Foreign Trade Zones All Rights Reserved
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Blueprint - Defining
Physical Area
The following is provided to CBP:
Map of entire area approved by FTZ Board may be
provided with ‗activated‘ area indicated
Generally, a blueprint of actual facilities is included with
the ‗activated‘ area indicated
Activated area can be altered as needed through
subsequent application to CBP
Operator must retain copy of most current
maps/blueprints showing activated area
©National Association of Foreign Trade Zones All Rights Reserved
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Gauge Table
Required in bulk processing zones including oil
refineries
Gauge tables showing the capacity in the
appropriate unit of any tank, as applicable
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Procedures Manual
Purpose
Describes methodology of all zone transactions
Must provide sufficient detail of zone operations for
Customs‘ understanding
Not so detailed that it can‘t be kept up to date, current
copy reflecting current operations must be on file with
Customs
Used as training document for employees
Must be submitted as part of activation request
©National Association of Foreign Trade Zones All Rights Reserved
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Procedures Manual
Identifies location of and activities conducted in
zone
Includes transportation and admission to zone,
activity in zone, transfer of merchandise from
zone
Describes process for preparing required periodic
reports
©National Association of Foreign Trade Zones All Rights Reserved
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Background Investigations
Who Managers of zone operations, key operational areas
Supervisors with access to zone records
Required Information (Requirements Vary by CPB Port) Name
Title
Current Address
SSN
Birth date
Place of birth
May require fingerprints
Background investigations should be started during application process due to time required
©National Association of Foreign Trade Zones All Rights Reserved
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Security
Port Director may conduct a security check
Guidelines for security are found in:
FTZ Manual, Chapters 4 and 8
Treasury Decision 72-56 ―Standards for Cargo
Security‖ booklet (Current electronic security
generally recognized as sufficient)
More stringent with focus on physical security of
imported goods rather than revenue protection
©National Association of Foreign Trade Zones All Rights Reserved
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FTZ Operator’s Bond
Port Director sets bond amount
Sufficient to cover potential duty on type of
merchandise admitted
Influenced by nature of merchandise
Risk incurred by CBP in processes authorized by
FTZ Board
Submitted to CBP on CBP301 by Operator
Bond requirements and amounts currently under
review by CBP Headquarters
©National Association of Foreign Trade Zones All Rights Reserved
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FTZ Operator’s Bond (con’t.)
Amount
Regulatory minimum - $50,000
Current minimum in practice $100,000
Bond Amount - Generally Customs duties owed on
average value of foreign non-duty paid inventory
Customs generally reviewing and increasing bond
amounts
©National Association of Foreign Trade Zones All Rights Reserved
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Grantee-Operator Agreement
Between grantee, operator, and/or user
Does not involve Customs
Terms and conditions for operating the zone
Responsibilities
Fees
Grantee typically provides grantee letter of
concurrence which must be provided to Customs as
part of activation request
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Census Bureau Reporting
Statement must be included in activation request
describing methodology of how Census Bureau
reporting requirements will be met
e214 filing
Required for cumulative daily reporting
Pink Statistical Copy of CBPF214
Single 214 per Bill of Lading
©National Association of Foreign Trade Zones All Rights Reserved
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Special Considerations
Requests for activation often contain requests for
procedures such as:
Direct delivery (of in-bond merchandise)
Authorization to break and affix Customs seals
Weekly estimated entry and export
CBPF 216 for manufacturing or manipulation
operations must be approved prior to
commencement of such activities
CBPF 216 issues under review for repetitive
manufacturing
©National Association of Foreign Trade Zones All Rights Reserved
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Approval
Application for activation may be reviewed/issued by
Service Port Director
Issued in writing specifying approval of:
Activation
Special Procedures requested
Approval typically requires 30 days
Can be reduced through prior communications with
CBP
©National Association of Foreign Trade Zones All Rights Reserved
INVENTORY CONTROL &
RECORDKEEPING SYSTEMS
©National Association of Foreign Trade Zones All Rights Reserved
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Regulatory Overview
Part 146, Subpart B, of CBP Regulations requires
each operator to have an inventory control and
record-keeping system (ICRS)
CBP reviews, but does not approve ICRS
FTZ operator responsible for inventory control
System must be documented in procedures manual
May be manual, automated or combination
©National Association of Foreign Trade Zones All Rights Reserved
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Regulatory Requirements
Account for all merchandise
Foreign status (NPF, PF, ZR)
Domestic status
Temporarily deposited
Temporarily removed
Produce accurate and timely reports
Identify shortages and overages
Record quantity, description, HTS number, zone
status, value
©National Association of Foreign Trade Zones All Rights Reserved
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Provide Audit Trail
Document merchandise transferred into and out of
zone
Provide audit trail from admittance to transfer
Ability to relate documents used for zone
removal to documents used for zone admission
A real plus would be the ability to audit from time
of order placement to time of payment
Must be readily available for CBP inspection and/or
audit
©National Association of Foreign Trade Zones All Rights Reserved
FTZ LOT SYSTEM
©National Association of Foreign Trade Zones All Rights Reserved
98
Specific Identification
Physical merchandise within zone is traceable to
the specific CBPF214 that recorded admission
Physical merchandise reconciled within lot
When removing merchandise must specify the
exact lot from which the merchandise is physically
removed
©National Association of Foreign Trade Zones All Rights Reserved
Lot System Example
Shipment 1
50 radios – Japan
Shipment 2
50 radios – Canada
©National Association of Foreign Trade Zones All Rights Reserved
Lot System Example
Lot 1
50 radios – Japan
Lot 2
50 radios – Canada
©National Association of Foreign Trade Zones All Rights Reserved
Lot System Example
Lot 1
50 radios – Japan
Lot 2 50 radios – Canada
Meanwhile, back in the
office . . .
The sales manager receives
an order for 50 radios. He
passes the order on to the
shipping department, telling
them to take the shipment
out of Lot 1.
©National Association of Foreign Trade Zones All Rights Reserved
Lot System Example
Lot 1
50 radios – Japan
Lot 2 50 radios – Canada
Out in the warehouse . . .
The warehouse worker is ready
for his morning coffee break and
wants to get this one last order
completed before he goes.
Maybe he doesn’t realize the
difference between Lot 1 and
Lot 2 . . .
Or maybe Lot 2 was simply
closer.
©National Association of Foreign Trade Zones All Rights Reserved
Lot System – Do we have a problem?
Lot 1
50 radios – Japan
Lot 2 0 radios – Canada
Lot 1
0 radios – Japan
Lot 2
50 radios – Canada
Warehouse Location FTZ ICRS
©National Association of Foreign Trade Zones All Rights Reserved
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Lot System Example
Our records show that we have no radios in Lot 1
and 50 radios in Lot 2. That is what Customs
expects to see in the warehouse.
But in the warehouse, there are 50 radios in Lot 1
and no radios in Lot 2.
Result – TWO merchandise errors (where penalties
can be equal to the value of the merchandise)
©National Association of Foreign Trade Zones All Rights Reserved
UNIQUE IDENTIFIER NUMBER (UIN)
©National Association of Foreign Trade Zones All Rights Reserved
106
Recordkeeping Identification
Relies on recordkeeping rather than physical control
Inventory tracking by a unique identification number
(UIN) assigned to specific item
Part Number, Stock number
Style Number, Raw material code
All receipts of that product must be fungible
(commercially interchangeable)
May have varying zone statuses within a single UIN
May have varying values, countries of origin
©National Association of Foreign Trade Zones All Rights Reserved
107
Record-keeping Identification
Information maintained upon receipt of UIN
UIN, Description, Date admitted, Quantity
Country of origin, Zone status, Value
CBPF214 Number, HTSUS Number
Each receipt becomes a ―layer‖ of inventory on
paper
Inventory totals reconciled within UIN rather than
within a lot indicated on CBPF214 that admitted
merchandise
Check book inventory system
©National Association of Foreign Trade Zones All Rights Reserved
108
Inventory Relief Methodology
Used to identify which admission records will be used to
determine information required on the entry filed when
goods removed from the zone
First In, First Out (FIFO) most common
Foreign First (FOFI) export oriented zone. Very rarely
used. Usually where same material is both domestic
and foreign sourced. May work in dual source
Other methodologies must be approved by Customs
Headquarters ruling on a case by case basis
©National Association of Foreign Trade Zones All Rights Reserved
109
UIN Rationale
If all merchandise admitted to zone were to be
transferred from zone, CBP would receive all duty
owed based on admission and shipment
information
Physical control over gross quantities rather than
individual receipt quantities
©National Association of Foreign Trade Zones All Rights Reserved
UIN System Example
Shipment 1
50 radios – Japan
100 batteries – Japan
100 CD players – Germany
500 DVD players -- Canada
Shipment 2
50 radios – Canada
100 batteries – Germany
100 CD players – Japan
500 DVD players -- Japan
©National Association of Foreign Trade Zones All Rights Reserved
UIN System Example – Into warehouse
Location 1
50 radios – Japan
50 radios -- Canada
Location 2
100 batteries – Japan
100 batteries – Germany
©National Association of Foreign Trade Zones All Rights Reserved
UIN System Example – Into ICRS
Same two shipments received, plus additional shipment
of radios from the US
UIN Date Qty e214 CoO Value USD Status Date Qty 3461/7501 CoO Value Status Balance
Radio 1/2/2009 50 1 JP $115 N 50
Radio 1/2/2009 50 1 CA $110 N 100
Radio 1/5/2009 50 2 US $100 D 150
RECEIPT SHIPMENT
©National Association of Foreign Trade Zones All Rights Reserved
UIN System Example – Into ICRS
113
Meanwhile, back in the
office . . .
The sales manager receives
an order for 25 radios. He
passes the order on to the
shipping department, telling
them to ship the order today.
Location 1
50 radios – Japan
50 radios – Canada
50 radios - US
©National Association of Foreign Trade Zones All Rights Reserved
UIN System Example – ICRS
25 radios shipped under FIFO method
UIN Date Qty e214 CoO Value USD Status Date Qty 3461/7501 CoO Value Status Balance
Radio 1/2/2009 50 1 JP $115 N 50
Radio 1/2/2009 50 1 CA $110 N 100
Radio 1/5/2009 50 2 US $100 D 150
Radio 1/6/2009 25 AAA-1234567-8 JP $115 N 125
RECEIPT SHIPMENT
©National Association of Foreign Trade Zones All Rights Reserved
UIN System Example:
Warehouse
Location 1
25 radios – US
50 radios – Canada
50 radios – Japan
Out in the warehouse,
the radios had been
stacked in the order
received. The ones
from the US are on top
– and the warehouse
person pulls 25 US
radios. Do we have a
problem?
©National Association of Foreign Trade Zones All Rights Reserved
UIN System Example - ICRS
No problem
CBP just cares that there are 125 out on the shelf
Does it matter than they came from the US instead
of JP?
No problem
Customs looks only at records – not the parts
Except to count them, of course!
©National Association of Foreign Trade Zones All Rights Reserved
117
Inventory Control in Petroleum
Refineries
Totally different inventory that is neither specific identity (lots) or UIN FIFO or FOFI
See 19 CFR §146 Subpart H
Attribution method is used in which all final products are associated to a feedstock admitted
Most but not all FTZ refineries use ―producibility‖ (see T.D. 66-16) in which assignment is based on industry acceptable yields of production or the quantity of finished goods that could have been produced not necessarily what was produced
Originally adopted in the 1960s for drawback and authorized by FTZ law change for FTZs
©National Association of Foreign Trade Zones All Rights Reserved
Lot vs. UIN
Which is best for your company?
The one that most closely reflects the way
your company manages its inventory and
distribution/manufacturing systems
General Purpose Zones
Lot System
Limited number of receipts with unique merchandise in
each receipt
Space allocation sufficient so lot can remain together
rather than be put away by type of merchandise
UIN System
Small or large scale distribution with repetitive receipts of
SKU numbers©National Association of Foreign Trade Zones All Rights Reserved
119
UIN in Manufacturing
FTZ (purchased) components are admitted to the
zone in layers
FTZ components are released into the manufacturing
process
Use of existing inventory system
Material requirement planning (MRP) system
Issues to production work orders
Intermediate products
Identify the component parts consumed in the
finished good or sub assembly for FTZ quantity
reconciliation
©National Association of Foreign Trade Zones All Rights Reserved
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UIN in Manufacturing (con’t.)
Finished production
Report quantity of actual product removed
Determine FTZ components contained in products
removed
Bill of Material/Work Order
Backflush/Charged to Production
FTZ inventory depleted and valued based on the
layering of the quantity of components in the finished
products removed from zone
©National Association of Foreign Trade Zones All Rights Reserved
121
ICRS Specific Information
Admissions
CBPF214 number (indicated on CBPF214 or in e214 record)
Date admitted
UIN (part number, stock number)/Lot number
Description
HTS Quantity (actual quantity)
Value (price paid or payable)
Country of origin (country of manufacture)
Zone status (may vary admission to admission)
HTS Number (for goods as admitted)
Charges
©National Association of Foreign Trade Zones All Rights Reserved
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ICRS Specific Information
Zone Removals
Item actually shipped
UIN of FTZ components within item shipped
(may be the same as item shipped)
HTS of item shipped, FTZ components
Quantity of item shipped, FTZ components
Where shipped (import, export)
©National Association of Foreign Trade Zones All Rights Reserved
123
ICRS Specific Information
Adjustments:
May be based on:
Annual physical inventory with Customs notification OR
Cycle counts
Discrepancies must be recorded in inventory and
recordkeeping systems
Discrepancies reported to Customs upon
identification over 1% of the quantity and $100 in duty
owed (19 CFR §146.53(a)(3))
©National Association of Foreign Trade Zones All Rights Reserved
124
ICRS Annual Information Required
Summarized information
YTD Beginning Balance
Cumulative Receipts
Cumulative Withdrawals
Adjustments
Current Balance
Records reconciled to physical balances
Annual Reconciliation
Cycle Counts
©National Association of Foreign Trade Zones All Rights Reserved
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Audit Trail:
Admission to Removal
Track CBPF214 Number to Entry Number(s)
System must demonstrate what should still be within zone
UIN System: Total quantity remaining on admissions
for UIN
Lot System: Lot Balances
System must demonstrate how and when ―removed‖
inventory was reported to Customs
Consumption Entry (CBPF 7501)
In Bond Entry (CBPF 7512)
Scrap (CBPF 216)
©National Association of Foreign Trade Zones All Rights Reserved
126
Audit Trail:
Removals Back to Admissions
Trace entry number to CBPF214 number(s)
System must be able to demonstrate that inventory
methodology preserved (FIFO)
System must be able to demonstrate that
information reported on removal from the zone can
be directly related to information reported upon
admission
Does the information on the entry match the
information reported on the admission?
Value, Country of Origin, Zone Status Impact
©National Association of Foreign Trade Zones All Rights Reserved
127
Company System as FTZ System
Audit trail is where most company systems
inadequate
Direct link (whether physical or systemic) between
individual receiving records and individual shipping
records is not crucial to most company operations
General attitude: ―If we have some, ship it!‖
©National Association of Foreign Trade Zones All Rights Reserved
128
Relationship to Existing Systems
Data available within company systems
Quantity
Date Admitted
Value
Supplier
Company data maintained differently
Usually in summary form
Receipt by receipt visibility lost once enters process
Company system has greater tolerance for
discrepancies
©National Association of Foreign Trade Zones All Rights Reserved
129
Relationship to Existing Systems
FTZ system should parallel company system
Must reflect how company operates
Artificially imposed systems generally do not
succeed
Use company information where it is most accurate
Receiving
Shipping
©National Association of Foreign Trade Zones All Rights Reserved
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Relationship to Existing Systems
FTZ system should use information from the
company system
Tracks CBP compliance information
Must have ability to adjust for:
Reality vs. planned inventory actions
Human errors
©National Association of Foreign Trade Zones All Rights Reserved
131
Relationship to Existing Systems
Company records used to support FTZ records
Receiving records, quality inspections, purchase
orders, customer returns
Storeroom receipts, issues, WIP tracking,
production reporting
Customer orders, customer shipments, work
orders, inventory write offs, scrap write off
Adjustment processing
©National Association of Foreign Trade Zones All Rights Reserved
132
FTZ Inventory Planning
Groups to involve
Accounting personnel (money)
Material planning (merchandise)
Procurement
Sales
Transportation (logistics)
Manufacturing (consumption)
Warehouse (release)
Quality Assurance (approval)
Information technology (data)
©National Association of Foreign Trade Zones All Rights Reserved
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FTZ Inventory Planning
Document flow of material from arrival to transfer
out of zone
Listen carefully for exceptions to normal flow of
material - no matter how small or infrequent
Rejected materials, misshipments, testing, off-
site activity, customization, returns
Identify action currently taken
©National Association of Foreign Trade Zones All Rights Reserved
134
Key Questions to Ask
How are material shortages handled? in production?
in shipping?
How is material, production quality ensured?
What is done when material is rejected?
How are product changes implemented?
What is done with scrap or waste material?
Is sampling done?
How are customer returns handled?
©National Association of Foreign Trade Zones All Rights Reserved
135
Exceptions = Rule
Recognize that exceptions are the norm
Identify ways to get exception reports
Understand impact of exceptions on FTZ inventory
Does it cause removal (shipment) from zone?
Does it change identity of material?
Does it have no impact on total inventory?
©National Association of Foreign Trade Zones All Rights Reserved
136
FTZ Inventory Reality
FTZ system must be flexible to allow for corrections
for exceptions, human errors
FTZ requires accurate receipts, bills of material/
work orders, and shipments
©National Association of Foreign Trade Zones All Rights Reserved
137
FTZ Inventory Success
Know and involve key individuals directly responsible
for material accountability
Establish communication lines
Ask questions, know what is happening in the
company
Don‘t just sit in an office surrounded by paper and
numbers
©National Association of Foreign Trade Zones All Rights Reserved
138
FTZ Inventory Success
Keep systems as simple as possible
Know CBP requirements
Be able to explain system to CBP
Be able to explain CBP to the company
COMMUNICATE!
©National Association of Foreign Trade Zones All Rights Reserved
FTZ PROCESSING
©National Association of Foreign Trade Zones All Rights Reserved
140
General Information
Merchandise may be admitted into FTZ unless it is
prohibited by law
Restricted merchandise may be placed in FTZ
Subject to FTZ regulation based on public interest
Bonded Warehouse merchandise may be admitted in ZR
status
Check on your particular situation
©National Association of Foreign Trade Zones All Rights Reserved
FTZ Merchandise May Be
stored
exhibited
broken up
repacked
assembled
distributed
sorted
graded
cleaned
mixed with foreign and
domestic merchandise
destroyed
title transferred
otherwise manufactured
or manipulated without
being subject to U.S.
Customs laws
©National Association of Foreign Trade Zones All Rights Reserved
142
FTZ Limitations
FTZ Board may deny permission to manipulate,
manufacture, or exhibit merchandise in order to
protect public interest, health or safety
Certain products subject to an internal revenue tax
(i.e., alcoholic beverages) may not be
manufactured in a zone
Limitations exist for retail trade in FTZ
©National Association of Foreign Trade Zones All Rights Reserved
AUDIT-INSPECTION
REGULATION OF FTZS
©National Association of Foreign Trade Zones All Rights Reserved
144
Access to Zones –
Audit Inspection
Customs officers permitted access to zone to conduct
audits, spot checks, or other lawful purposes
Operator should cooperate in spot checks, audits, or
other lawful actions
Audit inspection, began in 1986, based on six
principles which follow
©National Association of Foreign Trade Zones All Rights Reserved
145
Six Principles of Audit-Inspection
1. Determination of identity and nature of merchandise
before or upon deposit in zone
2. Issuance of a prior permit by CBP for receipt,
delivery from zone, and processing in zone
3. Assumption of responsibility by operator for
merchandise in zone
©National Association of Foreign Trade Zones All Rights Reserved
146
Six Principles of Audit-Inspection
4. Performance by CBP of audits and compliance
reviews to verify operator compliance
5. Adequate bonding of operator and assessment of
liquidated damages by CBP to assure compliance
6. Authority for CBP to suspend activation or
recommend revocation to FTZ Board of any zone
grant not complying with laws and regulations
©National Association of Foreign Trade Zones All Rights Reserved
147
Spot Check
(Compliance Review)
Frequency based on a port‘s risk assessment of
an individual zone, usually at least annually
CBP physically observes or examines records,
transactions, procedures, or conditions Determines operators and users are in compliance with
applicable laws, regulations and procedures
Provides CBP auditors with information in planning and
conducting audits of zone records
©National Association of Foreign Trade Zones All Rights Reserved
148
Spot Check
(Compliance Review)
Usually made without advance notification
Company representative invited but not required to
be present (company should require CBP be
escorted at all times!)
Usually limited in time to one or two days
Frequency depends on CBP assessment of risk
May involve quantity count of selected UINs and
reconciliation to admission file / inventory records
In manufacturing operation, emphasis placed on
receipt and shipment into operator‘s records
©National Association of Foreign Trade Zones All Rights Reserved
149
Compliance Assessment
Begun October 1, 1995, Renamed ―Focused
Assessments in 2002/2003
Employs statistical sampling techniques
Uses audit procedures with emphasis on importer‘s
internal controls
Highlights principles contained in Mod Act
Customs strives for importer compliance rather that
revenue collection
©National Association of Foreign Trade Zones All Rights Reserved
ENFORCEMENT
©National Association of Foreign Trade Zones All Rights Reserved
151
FTZ Enforcement Actions
Range from warning notices to criminal sanctions and
jail sentences
Sanctions should be fair, not unduly burdensome as
FTZs provide an important service to importing
community
Sanctions should be commensurate with seriousness
of violation
Warning notices
Liquidated damages
Fines / Penalties
Incarceration
©National Association of Foreign Trade Zones All Rights Reserved
152
Fines, Penalties, Forfeitures,
Liquidated Damages
Criminal Sanctions for Willful Violations
Civil Sanctions 19 U.S.C. §1592, FTZ Regulations
Failure to keep adequate records
Failure to account for merchandise entering, leaving or
remaining in zone
Shortages, overages
©National Association of Foreign Trade Zones All Rights Reserved
153
Fines, Penalties, Forfeitures, Liquidated
Damages
Section 592 Penalties –
Negligence
Gross Negligence
Fraud
Prior Disclosures
Liquidated Damages – FTZ Operator‘s Bond
Violations of FTZA subject to max. fine of $1000 per
day
Further action could be suspension of activation
and/or recommendation of revocation to FTZ Board
©National Association of Foreign Trade Zones All Rights Reserved
154
W A R N I N G
YOU ARE ENTERING A US FOREIGN-TRADE ZONE
Whoever maliciously enters with intent to remove any
merchandise, or unlawfully removes merchandise from US
Customs and Border Protection custody or control shall be
guilty of a federal crime and fined not more than $250,000 or
imprisoned not more than ten years or both. Persons and
conveyances entering and leaving this zone are subject to
examination. 18 USC 549, 3571
©National Association of Foreign Trade Zones All Rights Reserved
FTZ ADMISSIONS
©National Association of Foreign Trade Zones All Rights Reserved
156
Admission
Admit means to bring into zone with zone status
Admission vs. entry
Conditionally admissible -- Grant Restriction
©National Association of Foreign Trade Zones All Rights Reserved
157
First Inventory
Where does it come from?
What is its status?
©National Association of Foreign Trade Zones All Rights Reserved
158
Admissions Documentation
CBPF214
Required for all foreign-status (NPF, PF)
Required for zone-restricted merchandise
Could be required for domestic merchandise
Admissions information may be filed electronically
using e214 process
Available through ABI system
©National Association of Foreign Trade Zones All Rights Reserved
159
Admissions Documentation
Supporting Documentation
Two copies of commercial invoice
Bill of Lading
In-bond documentation for movement from port of arrival if different from zone port
Evidence of right to make entry
Carrier release order
And any other information required by Customs
CBPF 214A required for transmission by Customs to the Census Bureau if e214 not used (pink copy)
©National Association of Foreign Trade Zones All Rights Reserved
160
Purpose of Admission Documentation
Establish identity of merchandise admitted
Type of merchandise
Quantity
Value
Establish zone status for treatment of merchandise
Establish CBP liability of operator
Submit information about import to Census
©National Association of Foreign Trade Zones All Rights Reserved
161
Types of CBPF214
Standard 214
Based on BOL
Customs‘ release required prior to delivery to zone
Blanket 214
Shipments arrive under multiple CBP in bond
transportation documents
Shipments which are destined to same zone
applicant on single business day
Must use e-214
Customs authorization is required
©National Association of Foreign Trade Zones All Rights Reserved
162
Types of CBPF 214
Cumulative
Reports all admissions for single day
Available only in direct delivery operations (19 CFR
146.39)
File written application with Port Director at least 30 days to
approve procedure.
Port Director shall approve if:
Goods are not restricted, and
Merchandise and subsequent operations known, predictable,
fixed by business conducted at site, and
The operator is the owner of goods
Requires use of e214
©National Association of Foreign Trade Zones All Rights Reserved
163
Zone-to-Zone Transfers
Special attention paid to zone status of goods
received from another zone
Certain restrictions may apply based on zone
status election at first zone
Forwarding documentation history closely
monitored to ensure compliance
No Census reporting required
©National Association of Foreign Trade Zones All Rights Reserved
164
CBPF 214 Attachments
Documents required to prepare CBPF 214
Bill of lading
In-bond document
Commercial or proforma invoice
Packing List or Receiving Report
©National Association of Foreign Trade Zones All Rights Reserved
165
Merchandise Examination
Port Director may cause merchandise to be
examined or authorize delivery to zone without
examination under a Standard Admission
Direct delivery procedures allow cargo to move to
zone without examination
©National Association of Foreign Trade Zones All Rights Reserved
166
Merchandise Examination
Objectives of examination
Are the goods admissible?
Determine liability of zone operator
Reduce the need for exam
Future admissions
Upon removal
Ensure compliance with all applicable laws and
regulations
At CES/CFS, Zone or elsewhere
©National Association of Foreign Trade Zones All Rights Reserved
167
Document Review
Customs may waive requirement for presentation of
supporting documents
Documents must be retained at zone
Customs reviews documents and supporting
documentation for completeness and accuracy
©National Association of Foreign Trade Zones All Rights Reserved
168
Permit to Transfer/Admit
Permit to transfer allows in bond movement to zone
within port boundaries once authorized by CBP
Officer
CBP approval for admission occurs when:
Admission application properly executed with all
data completed accurately
Operator has approved admission application
Any required examination completed
All requirements fulfilled
©National Association of Foreign Trade Zones All Rights Reserved
169
Arrival at the Zone
Operator checks
CBPF214 for required signatures
Seals on conveyances
Description, quantities against packing list
Operator unloads into activated area
©National Association of Foreign Trade Zones All Rights Reserved
170
Admission Process
Paper Standard Admission
CBPF214 completed and
authorized by:
Operator – Agrees to
accepting goods at FTZ
In-Bond carrier - Accepts
liability during transit
CBP - Authorizes
designation of zone status
and admission to FTZ
Goods transferred to FTZ
Operator - Concurs delivery
of all goods and returns
CBPF214 to CBP
Electronic Standard Admission
Operator - Transmits CBPF214
data
CBP accepts CBPF214 data
Operator - Transmits Accepted
Quantity Not Verified
Operator - Transmits ePTT
Goods transferred to FTZ
Operator - Transmits Arrival
Operator - Transmits Final
Concurrence
©National Association of Foreign Trade Zones All Rights Reserved
171
Admission Process
Electronic Direct Delivery
Admission
Operator – Transmits ePTT
Goods transferred to FTZ
Operator - Transmits Arrival
Operator - Transmits CBPF214
data
Operator - Transmits Final
Concurrence
Paper Direct Delivery
Admission
Operator/Freight Forwarder –
Completes PTT
Goods transferred to FTZ
Operator verifies goods,
completes CBPF214 and
sends to CBP
CBP - Authorizes designation
of zone status and admission
to FTZ
©National Association of Foreign Trade Zones All Rights Reserved
172
Discrepancies
Operator reports to the Port Director any discrepancies
If paper CBPF214 filed On the CBPF214 in block 46 if discovered immediately
On a copy of the CBPF214 if within 15 days after admission
On a Manifest Discrepancy Report (MDR) within 20 days after admission
If e214 and direct delivery, identify discrepancy on e214 for overage
If e214 and direct delivery, identify shortage by MDR to carrier and correct quantity received on e214
If e214 and standard admission, through filing of replacement e214
©National Association of Foreign Trade Zones All Rights Reserved
173
Admission (at Last)
Inventory Identification Requirements
Under LOT SYSTEM, Operator marks packages
with the zone lot number
Under UIN SYSTEM, no special marking is
required
Operator signs the CBPF214 and accepts zone
liability for the merchandise
©National Association of Foreign Trade Zones All Rights Reserved
174
Time of Admission
Merchandise is admitted only when
Customs has properly approved the
CBPF214, establishing the zone status
Operator has signed for receipt into the
activated area of the zone, accepting
liability under its FTZ Operator‘s Bond
©National Association of Foreign Trade Zones All Rights Reserved
175
Domestic Merchandise
No CBPF214 required unless requested by the
Commissioner of Customs
Recorded in receiving report or system
May physically be brought into the activated area of
a zone
©National Association of Foreign Trade Zones All Rights Reserved
176
Production Equipment
Production equipment is in general machinery used
for manufacturing operations
Check on status before admission
May be admitted without payment of duties until
completely assembled, installed, tested and used in
full scale production
Importer must furnish certification that duties will be
paid when production commences (on CBP 214)
Merchandise shall be subject to classification
according to its character, condition, and quantity
and the rate of duty applicable at the time the
equipment is used in production – PF/NPF status
©National Association of Foreign Trade Zones All Rights Reserved
177
Other Admission Issues
Temporary Importation Under Bond
Transfer from a Bonded Warehouse
Temporary Deposit
©National Association of Foreign Trade Zones All Rights Reserved
178
Harbor Maintenance Fee (HMF)
Applied at a rate of 0.125% of entered value for
imported cargo unloaded from a commercial vessel
at a U.S. port subject to the fee (19 CFR §24.24)
Paid quarterly instead of at admission
Exports are not subject to HMF
CBP focusing on payments being made within 31
days of end of quarter
©National Association of Foreign Trade Zones All Rights Reserved
HANDLING GOODS IN FTZ
©National Association of Foreign Trade Zones All Rights Reserved
180
Storage Conditions
Zone will be safe for personnel
Merchandise will be protected from theft, loss,
damage, and deterioration
Compliance Reviews, inventories, and audits can
be performed efficiently by Customs and zone
personnel
Zone will not endanger the public health or safety
©National Association of Foreign Trade Zones All Rights Reserved
181
Manner of Storage
Aisles will be established and maintained, and
doors and entrances left unblocked, for entrance by
Customs officers and other persons in performance
of their official duties
Port Director may require segregation of any zone
status merchandise when necessary to protect the
revenue or properly administer U.S. laws
©National Association of Foreign Trade Zones All Rights Reserved
182
Activated Area
No zone status merchandise shall be stored,
even temporarily, outside the activated area
except:
Merchandise covered by a temporary
removal permit, or
Domestic merchandise for which no permit is
required
©National Association of Foreign Trade Zones All Rights Reserved
183
Application to Manufacture, Manipulate
or Destroy
Application Process (19 CFR §146.9)
Operator must file CBPF216 prior to
manufacture, manipulation or destruction of
merchandise admitted to zone
May be blanket (annual) or single transaction
©National Association of Foreign Trade Zones All Rights Reserved
184
Activities Authorized
Manufacturing - A process resulting in a tariff
classification change or creation of new article of
commerce
Exhibition - Display of merchandise
Destruction - Complete destruction resulting in no
recoverable residue of any commercial value
Manipulation – Repacking, sorting of merchandise
that does not change merchandise
©National Association of Foreign Trade Zones All Rights Reserved
185
Submission of CBPF 216
Must be filed by the operator
Description of activity must be detailed so Port Director
can determine whether permit should be approved
Individual 216 must be detailed
Blanket 216 should describe merchandise in detail but
not required to provide yearly quantity, value, etc.
For continuous or repetitive operation
May include destruction with Port Director approval
Port Director may return the application for correction
Change in operation not described in original 216
requires a re-filing of application
©National Association of Foreign Trade Zones All Rights Reserved
186
CBPF 216 Recordkeeping
Upon approval, Port Director should return a copy
of the CBPF216 to the operator
The operator retains the approved application with
its zone records.
Port Director may revoke any blanket permit and
require the filing of individual CBPF216s
Decision may be appealed
©National Association of Foreign Trade Zones All Rights Reserved
187
Approval of CBPF 216
The Port Director will approve the application unless:
The proposed operation would be in violation of
law or regulation
Place designated for operation is not suitable
The Executive Secretary of the FTZ Board has not
granted approval of the manufacturing operation
©National Association of Foreign Trade Zones All Rights Reserved
188
Destruction
Method of destruction shall be stated in the
application
Method must be sufficient to assure merchandise is
completely destroyed
Note: Sale of scrap to recycler does not constitute
destruction since there is residual value but must
be covered by the 216.
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Approval of Destruction
Application shall be approved unless:
Proposed destruction would be in violation of law
or regulation
Place designated for performance is not suitable
Port Director not satisfied destruction will be
effective, complete, and carried out in safe manner
Destruction permitted outside the zone
Conditions exist to protect the revenue
Cannot be accomplished in zone
Hazardous materials
©National Association of Foreign Trade Zones All Rights Reserved
190
Supervision of Destruction
At discretion of Port Director
Particularly important for restricted merchandise
Residue of destruction with no commercial value may
be transferred to Customs territory
If Port Director does not supervise, operator
completes bottom portion of CBPF216
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Destruction of Alcohol
Distilled spirits, wines, and fermented malt liquors
may not be admitted in ZR status for the purpose of
destruction
Destroyed only with permission from ATF (Section
146.44(c))
Destruction may be physically supervised at
discretion of Port Director
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192
Country of Origin Marking
Distribution – No origin change from FTZ receipt
Manufacturing in a zone – may cause substantial
transformation
New FTZ manufactured product
May no longer be considered an article of foreign origin
United States becomes country of origin
Not necessary to be marked Country of Origin: USA
Do not use ―Made in USA‖ or similar language
―Assembled in the U.S. with foreign and domestic
components‖ may be permitted
©National Association of Foreign Trade Zones All Rights Reserved
193
Country of Origin Marking
Goods may be admitted to zone without or with
improper country of origin marking
Permission to mark country of origin requested on
CBPF216 (manipulation) – Individual 216
©National Association of Foreign Trade Zones All Rights Reserved
REMOVAL OF MERCHANDISE FROM
FTZ
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195
Temporary Removal
Upon permit, zone status merchandise may be
removed up to 120 days for repair, restoration, or
incidental operations such as testing, photography,
examination, etc.
Application shall be made on individual CBPF216
No extensions granted beyond the 120 days
All merchandise removed from the zone must be
returned to the same FTZ
©National Association of Foreign Trade Zones All Rights Reserved
196
Conditions for Temporary Removal
Merchandise may not be removed before
application is approved
Except for repairs, no other merchandise may be
added to, combined with, or incorporated in
removed merchandise, and no value may be added
Quantities removed and returned must be balanced
©National Association of Foreign Trade Zones All Rights Reserved
197
Return of Temporary Removals
Operator shall certify the return of merchandise on a
CBP216 and forward to Port Director
Merchandise shall be returned in same zone status it
had upon removal
If merchandise is not timely returned to the zone, it
shall be considered to have been transferred from the
zone without a permit
Violation considered a merchandise default
©National Association of Foreign Trade Zones All Rights Reserved
198
Transfer of Merchandise
Entry into U.S. commerce
Normal entry procedures made on a Type
―06‖ CBPF 7501
Zone-to-zone transfers
Merchandise may be transferred between
zones in-bond without entry
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Transfer of Merchandise from FTZ
Duty deferral entry/claim (NAFTA) made on a
CBPF 7501
In bond export from zone made on a CBPF 7512
Only for manufactured goods exported to Canada and
Mexico
Requires U.S. entry and duty payment on non-NAFTA
material
Type 08 or 06 entry
©National Association of Foreign Trade Zones All Rights Reserved
200
Release and Transfer
Removal of domestic merchandise does not require
Customs permit
Removal of foreign merchandise requires Customs
permit
Consumption Entry
In-bond Removal
In-transit (IT - 61)
Transportation and Export (T&E - 62)
Immediate Export (IE - 63)
Applied for by importer of record
©National Association of Foreign Trade Zones All Rights Reserved
201
Release and Transfer
Merchandise for which a permit has been issued must
be physically removed within five working days
Unless included on estimated weekly entry for
consumption or in-bond movement
Unless extended time has been approved by Port
Director
©National Association of Foreign Trade Zones All Rights Reserved
202
Administrative Exceptions
Port Director may allow constructively transferred
merchandise to remain in the zone for extended
period if the importer provides in writing:
Merchandise will not be further manufactured so
as to effect a change in tariff classification
Operator will provide a proper audit trail to verify
merchandise was not changed after entry
©National Association of Foreign Trade Zones All Rights Reserved
203
Time of Transfer
A proper permit to transfer must be issued by Customs to Importer of Record (not operator)
Merchandise is then ‗released‘ to operator
Operator releases merchandise to carrier, importer who has signed to physically remove the merchandise from the activated area of the zone
©National Association of Foreign Trade Zones All Rights Reserved
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Entry for Consumption
Operator establishes point where goods enter commerce
of the US
Movement past that point out of the zone constitutes an
‗entry‘
At that point, goods become subject to all Customs and
other agency regulations pertaining to imported goods
©National Association of Foreign Trade Zones All Rights Reserved
205
Entry for Consumption
Permission to ―enter‖ goods into US Commerce filed by
Importer of Record
CBPF 3461 - Immediate Delivery/Entry used (type
06)
Request by Harmonized Tariff Number
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206
Entry for Consumption
In a manufacturing zone
Majority of goods entered as finished product
Merchandise may also be entered as
Parts in PF status
Repair Parts
Adjustments
In a general purpose zone/distribution zone merchandise entered is almost always in the same condition as admitted
Entry subject to selectivity just like any other entry
Once ―released‖ by Customs, goods can physically leave zone
©National Association of Foreign Trade Zones All Rights Reserved
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Entry for Consumption
Importer of Record has 10 working days to file Entry
Summary (CF7501)
Classifies, values, quantifies goods entered
Accompanied by payment of duty
On Importer‘s Bond, not Operator‘s Bond
Subject to review by Import Specialists
Must satisfy all entry regulations as if entered directly
from foreign country
Including requirements of other U.S. government
agencies
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208
HTS Classification
Along with any FTA or other preference program, will determine duty rate paid on goods removed from the zone
Determined by status selected at time of admission for merchandise removed
NPF will result in the use of the HTS of the product removed from the zone Manufacturing zones need to classify manufactured
products (subassemblies)
PF will result in the use of the HTS of the product as admitted to the zone – regardless of what it is when it is removed from the zone
©National Association of Foreign Trade Zones All Rights Reserved
209
Valuation
Dutiable value
Price actually paid/payable for merchandise in
transaction that caused the merchandise to be
admitted into zone, plus statutory additions
What the zone user paid for the merchandise
Total zone value
Price actually paid/payable to the zone seller in
transaction that caused merchandise to be
transferred from zone
Price for which the zone user sold the
merchandise
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210
Valuation
Value recorded at time of admission used to determine
value of entered merchandise
Manufactured Items
Dutiable value
Sum of value of all UINs with foreign status included in the
manufactured item
Not included:
Value of domestic material added
Value of US labor, overhead
Non-manufactured items
Value = admitted value
©National Association of Foreign Trade Zones All Rights Reserved
211
Country of Origin
Goods manufactured in FTZ
Foreign country with highest total value becomes
country of origin for Census reporting purposes
Any foreign status merchandise requires foreign
country of origin
Non-manufactured goods – no change in country of
origin
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212
Weekly Estimated Entries
Purpose of weekly entries
Provides for continuing rapid removal of goods from the zone
Permission for release from Customs custody based on
estimates of shipments
Weekly entry on CF 7501 after the week is over
Weekly entry allowed for manufacturing, storage, etc. (all
types of zones)
Weekly entry not permitted
Quota merchandise
Merchandise subject to FTZ Board restrictions on use (e.g.,
sugar)
©National Association of Foreign Trade Zones All Rights Reserved
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Weekly Estimated Entries
Estimate submitted to Customs on CBP3461
Estimate at HTS level, not UIN level
Establishes maximum quantity that can be removed
Can be a template used each week
Must be accepted and APPROVED by Port Director
before shipments begin for the week
Supplemental estimates can be filed if necessary
Do not exceed estimated quantity for the week
©National Association of Foreign Trade Zones All Rights Reserved
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Zone-to-Zone Transfers
In order to avoid payment of duty when shipping goods to another zone:
Goods transferred in-bond by a bonded carrier Licensed cartman (within port)
FTZ Operator of destination zone
Bonded carrier (between ports)
Customs form CBPF 7512 is required for in bond movement
Must be approved by Customs prior to removal of merchandise from the zone
Individual CBPF 7512 for each shipment or
Weekly zone-to-zone procedure for approval is available
©National Association of Foreign Trade Zones All Rights Reserved
215
Zone-to-Zone Transfers
(from one port to another port)
Can prepare and submit an individual CBP7512 for each unique shipment
Statements on CBPF 7512
Must state goods are FTZ goods
Indicate originating zone
Indicate zone status of goods
Requires CBP signature for each shipment
Liability is transferred to carrier‘s bond
Paper used when zone-to-zone moves are infrequent
Consider QP/WP option
©National Association of Foreign Trade Zones All Rights Reserved
216
Zone-to-Zone Transfers
(from one port to another port)
Weekly Zone-to-Zone Process
Estimated CBPF 7512 submitted and approved by
Customs beginning of week granting permission for
week‘s shipments
An individual CBPF 7512 still prepared for each
unique shipment leaving zone
Operator signs on behalf of Customs
Copy submitted to Customs after shipment for entry
into CBP in bond system
Consider QP/WP option
©National Association of Foreign Trade Zones All Rights Reserved
217
Zone-to-Zone Transfers
(within the same port)
Using electronic CBP permit to transfer system (ePTT)
or other approved locally approved process, mirror the
process used for transfers from port-to-port
CBPF 7512 not required for within port transfers
©National Association of Foreign Trade Zones All Rights Reserved
218
Zone-to-Zone Transfers
Upon arrival at receiving zone, a CBPF214 is filed to
accept liability for merchandise
Must be able to cross reference admission to second
zone with shipment from first zone which must tie back
to original admission
Care must be taken to ensure that zone status from
originating zone is retained on admission in receiving
zone
©National Association of Foreign Trade Zones All Rights Reserved
219
Exportation from Zone
Process is the same as for zone-to-zone transfers except:
Entry type on the CBPF7512 will be: Transportation and Export (T&E)
Immediate Export (IE)
Final destination will be foreign country
Weekly process is available (QP/WP)
Exporter must file Electronic Export Information (EEI)
©National Association of Foreign Trade Zones All Rights Reserved
220
Removal of ZR Merchandise
ZR status merchandise may be transferred to the
Customs territory:
For exportation (via T&E or IE)
For warehousing pending exportation
For destruction
For transfer to another zone (IT)
For delivery to a qualified aircraft (IT)
ZR status merchandise may be entered for
consumption only if approved by the FTZ Board as
being in the public interest
©National Association of Foreign Trade Zones All Rights Reserved
221
NAFTA
Purpose is to provide preferential duty treatment for
goods of parties to agreement
Special ‗safeguards‘ to prevent extending preferential
duty to goods imported from other countries used in
manufacturing/processing in special ‗zones‘ –
―platforming‖
Maquiladoras in Mexico
Inward processing zones in Canada
FTZs in the US
©National Association of Foreign Trade Zones All Rights Reserved
222
NAFTA Example 1
US duty rate = 2.5%; 2.5% of $5,000 (foreign
content) = $125 that would be paid to U.S.
Customs is declared
Canadian duty rate = 1.8%; 1.8% of $10,000
(total value) = $180 is paid to Canada Border
Security Agency (CBSA)
Duty Payment: $180 paid upon entry into
Canada documented to CBP, so US exporter
pays $0 (except MPF and any applicable
ADD/CVD)
©National Association of Foreign Trade Zones All Rights Reserved
223
NAFTA Example 2
US duty rate - 2.5%; 2.5% of $5,000 (foreign
content) = $125
Canadian duty rate - 0.9%; 0.9% of $10,000
(total value) = $90
Duty Payment: $90 paid upon entry into
Canada documented to CBP, so US
exporter pays $35 (plus MPF and any
applicable ADD/CVD)
©National Association of Foreign Trade Zones All Rights Reserved
224
NAFTA Example 3
US duty rate - 2.5%; 2.5% of $5,000
(foreign content) = $125
Canadian duty rate - 0%; 0% of $10,000
(total value) = $0
Duty Payment: so $0 paid upon entry into
Canada documented to CBP, and $125 (plus
MPF and any applicable ADD/CVD) paid to US
©National Association of Foreign Trade Zones All Rights Reserved
PERIODIC REPORTING
©National Association of Foreign Trade Zones All Rights Reserved
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Periodic Reporting
Discrepancy reporting and recording
Census Reporting – only paper 214
Harbor Maintenance Fees – CBP 349
Annual Report to the FTZ Board
Annual Reconciliation – CBP letter
Systems review – CBP letter
FTZ Board Annual Report to Congress
Blanket CBPF 216
©National Association of Foreign Trade Zones All Rights Reserved
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Discrepancy Reporting
Shortages, in writing and upon identification
Theft or suspected theft
Merchandise not properly admitted into zone (overages)
Shortages of 1% of the quantity in a lot or unique identifier
and subject to duties and taxes of $100
Overages of foreign status merchandise
File either
CBPF214
Customs Entry
Within 5 days after identification
Extension may be granted by Port Director
©National Association of Foreign Trade Zones All Rights Reserved
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US Bureau of the Census
Statistical data on all admissions to zone must be
reported
Via e214 - Census extracts electronically, or
If paper CBPF214, pink copy of CBPF214 filed
with CBP for forwarding to Census Bureau
Electronic Export Information (EEI) through
AESDirect (SED became EEI in Summer of 2008
when mandatory AESDirect filing became
mandatory)
©National Association of Foreign Trade Zones All Rights Reserved
229
Annual Report to FTZ Board
Information required for FTZ Board Annual Report
Beginning and ending value of inventory
Value of merchandise admitted
Value of merchandise removed
Narrative describing zone activities, benefits
Value added
Recently revised based on calendar year (January 1 through December 31)
Submitted electronically by Operator to Grantee
Forwarded to the Foreign-Trade Zones Board by the Grantee
©National Association of Foreign Trade Zones All Rights Reserved
230
Annual Reconciliation
Prepared by 90 days after end of zone year
Contains a description of merchandise showing zone
status, quantity on hand at beginning and end of
year, cumulative receipts and transfers (by unit), and
cumulative positive and negative adjustments (by
unit) made during the year
Operator shall submit certification letter within 10
working days after the report has been prepared
©National Association of Foreign Trade Zones All Rights Reserved
231
Annual Systems Review
Operator shall perform an annual internal review and
report any deficiencies to the Port Director
©National Association of Foreign Trade Zones All Rights Reserved
232
Reporting Responsibilities
Upon request, the operator shall report to the Port
Director
A list of officers or key employees within 30 days
after written demand
Any vehicle arriving with broken, missing, or
improperly affixed seals
©National Association of Foreign Trade Zones All Rights Reserved
233
CBP Reporting
In bond document for each FTZ admission
Daily admissions into zone
Weekly estimate for imports
Weekly entry with duty-payment
06/08 NAFTA entries for removals from the zone
Weekly estimate for exports – contra QP/WP
In-bond document for each export shipment
Weekly reconciliation of exports – contra QP/WP
More . . .
©National Association of Foreign Trade Zones All Rights Reserved
234
CBP Reporting
Quarterly HMF report and payment
Annual blanket CBPF216
Customs bonds (importer‘s, zone operator, and
custodial)
©National Association of Foreign Trade Zones All Rights Reserved
FTZ RECORD KEEPING
©National Association of Foreign Trade Zones All Rights Reserved
236
Record-Keeper
Owner, importer, consignee, importer of record, entry filer, or other person who:
Imports merchandise into US Customs territory, files a drawback claim, or transports or stores merchandise carried or held under bond
Knowingly causes importation or transportation or storage of merchandise carried or held under bond into or from US Customs territory
An agent of any person described above
A person whose activities require the filing of a declaration or entry, or both
©National Association of Foreign Trade Zones All Rights Reserved
237
Records to Customs
Be prepared to produce or transmit to CBP any
records CBP may demand
Records that are submitted to CBP and
subsequently returned, or
Records that were not reviewed by CBP at the time
of entry (paperless entries)
©National Association of Foreign Trade Zones All Rights Reserved
238
How Long? Record
Retention Requirements
5 years from date of entry
5 years from date of activity that created record
60 days after release/conditional period for packing lists
2 years from the date of the informal entry
2 years from the date of entry of duty-free merchandise
5 years after removal of merchandise from an FTZ
Other specific retention periods mentioned in § 163
©National Association of Foreign Trade Zones All Rights Reserved
239
Resources
Laws, Regulations, Rulings
FTZ Board
www.trade.gov/ftz
Customs resources
Statutes, regulations, rulings, cases
CBP FTZ Manual
www.cbp.gov
Zone grantee/operator
NAFTZ
www.naftz.org
Accredited Zone Specialists (AZS)
©National Association of Foreign Trade Zones All Rights Reserved
240
Questions?
For more information, please contact the NAFTZ Office:
1001 Connecticut Avenue, N.W.
Suite 350
Washington, D.C. 20036
(202) 331-1950
www.naftz.org
THANK YOU
©National Association of Foreign Trade Zones All Rights Reserved
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