QUESTION: Do FTZs offer any relief whatsoever from 301 duties? I keep finding this language, first published by CBP, and then reproduced by several law and consulting firms: Per the Federal Register Notice published by the USTR, any product covered by the Section 301 remedy … only may be admitted as “privileged foreign status” as […]
QUESTION: If we brought goods into our FTZ (properly admitted, etc) but then exported them without any removal paperwork (7512, etc), what’s our penalty exposure? Just $1000 or do we have other things to be wary of? ========== Answers: You could be sited for liquidated damages for unauthorized release, which may be mitigated down. It […]
QUESTION: We have 2 distribution centers within 30 miles of each other, and both are considered to be one FTZ. Each DC has a different site number, but still only have one zone number. Many of our ocean containers are split between the 2 DC’s, and we have permission from CBP to unload at the […]
QUESTION: We have a contract with a client to provide equipment for their refinery upgrade. The contract stipulates that we are to be the IOR for the equipment purchased. The client established the refinery site as a production FTZ after the contract was issued so the contract does not address this situation nor was the […]
QUESTION: Do any of the members have a detailed checklist to follow for FTZ Deactivation? I believe I know the basics: notify Port Director, Move all Goods out or to Domestic Status with Consumption Entry, Perform basic Final Accounting, Remove signs, Deactivate E-Mails, Terminate FTZ Bond, Allow CBP to do final walkthrough. Am I missing […]
QUESTION: My FTZ subzone grant requires everything I admit to my subzone be admitted as Privileged Foreign. I do that, every time. But the annual report to the FTZ Board asks for Beginning Value-Domestic Status as well. I don’t have any goods “admitted” with that status, but I do have many goods physically in the […]
QUESTION: I operate an FTZ subzone and one of my customs brokers just told me this concerning goods being admitted/leaving my Zone: As long as the goods go from the Port directly to my Zone, we can use my FTZ bond (Instead of requiring use of a trucking company with a transportation bond) to cover […]
QUESTION: After goods are admitted into my FTZ subzone, can I sell them to a third party? If so, whose responsibility is it to “remove” them from the FTZ? ========== Answers: Retail trade within an FTZ is prohibited. You can however do a “title transfer” to sell something to a third party. This is especially […]
QUESTION: Does anyone have a pdf of the FTZ Compliance Review Handbook, HB 3500-10? ========== Answers: Please see attached: https://www.icpainc.org/wp-content/uploads/2014/10/7450_OIG_15-76_Apr15-HB3500-10.pdf ==========
QUESTION: Please confirm or correct my understanding: Privileged foreign items are admitted into my FTZ subzone. If I want to export them, I need to use a bonded carrier to get them to the port? Is that my only option? Use a bonded carrier, which are rare here, or have my company get its own […]
QUESTION: How does CBP normally inform a party requesting activation of an FTZ of the approval? How many site visits do they normally do prior to approval? %%%%%%%%% ANSWERS:An activation approval should always be in writing – at which time CBP should also be assigning you the FIRMS code. We generally see two meetings – […]
QUESTION: My FTZ subzone is quite large, encompassing the whole of my manufacturing facility. many warehouses and storage yards. Does EVERY employee have to have a form 3078 on file? **************** Answers: No, every employee should be on your employee list, but in most ports, the 3078 should be just for those key employees. But […]
