Whether your company is new to the FTZ program or a “mature” FTZ operation, now is the time to undertake a comprehensive internal review of your FTZ and overall trade compliance in order to develop a true “audit preparedness” program and correct any identified compliance issues.
While the trade community was knee deep in its work last year of implementing trade modernization through the transition to ACE, CBP also took the opportunity to “modernize” its guidelines on physical security at CBP bonded facilities.
The U.S. Food and Drug Administration’s (“FDA”) Weekly Entry Filing (“WEF”) procedure for Foreign Trade Zones (“FTZs”) was instituted in the mid-1990s to provide a vehicle to “expedite entry of repetitive shipments of ‘low risk’ merchandise from FTZs in the United States.”
If your firm is an FTZ operator or user, you know firsthand the significant impact that ACE and PGA reporting requirements are having on our industry. By all accounts, the past 12 months have been a busy, often confusing time that’s been full of changes.
While the importing community is knee-deep in the on-going ACE implementation and deciphering Participating Government Agency requirements to meet upcoming deadlines, it is hard to believe that there could be other deadlines looming, but there are and this time it is for exports!
As the mandated transition to CBP’s Automated Commercial Environment (“ACE”) looms, trade has become all-too-familiar with the CBP catch phrase “Don’t Wait, Migrate!”, encouraging trade users to embrace the use of the ACE Portal.
Important Dates:
2/28/16—Mandatory filing of all electronic entries and entry summaries in ACE including 06 Entries (ACS will be decommissioned for entry/entry filing)
July/16—e214 transitioned from ACS to ACE
Sept/15—CATAIR for entry (cargo release) in ACE published by CBP
Oct/15—CATAIR for entry summary in ACE published by CBP
The long anticipated transition to ACE for entry summary and cargo release is just around the corner. The transition scheduled for November 1, 2015 will also include the opportunity to interface by electronic means with multiple and various Partner Government Agencies (“PGAs”) that will soon be on- boarding with ACE.
When the FTZ Board regulations (15 CFR Part 400) were revised in 2012, activities previously referred to as “manufacturing” or “processing” essentially were merged under one definition termed “production”. For FTZ operators and users, it is critical that the definition of production is fully understood so that the regulations and requirements pertaining to production can be complied with on an ongoing basis.
The FTZ Board regulations (15 CFR §400) require that each Grantee submit an annual report to the FTZ Board by March 31st each year. In turn, each year the FTZ Board submits the completed annual report covering activities of all zones to Congress.