In these current times of evolving trade policies, it is important that all stakeholders fully understand the possible impact of recent trade remedy measures on FTZ operations. This article summarizes the impacts and suggested actions for FTZ users, especially FTZ manufacturers.
On September 28th, the highly anticipated updated in-bond regulations were published in the Federal Register as a Final Rule set to take effect on November 27th, followed by a 90-day flexible enforcement period.
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.