Operations

There are only two customs forms (CFs) specifically related to zone admissions: CF 214 and CF 216. CF 214 is used for admission of foreign merchandise into a zone. Under most circumstances, no CF 214 is necessary for domestic status merchandise. The form is usually handled by a customs broker for the zone user or operator, but the operator may take responsibility for execution of CF 214s. Information included on a CF 214 is the same as the information on a customs entry form, except that it may also be used as a delivery ticket. One additional information item required on CF 214 is a declaration of the material's FTZ status.

For action to be performed on or with the merchandise, a CF 216 is required. The CF 216 is an application for activity. However, for a period of up to one year a blanket CF 216 may be filed, covering all types of activity anticipated. The operator must maintain records and document approved activities to provide an accounting and audit trail of the merchandise through the approved operation.

To remove material from a zone, the appropriate customs document must be filed: either a CF 3461 for entry into the U.S., or a CF 7512 for export or transfer to another U.S. zone. These documents are usually handled by a customs broker, unless the operator is also a licensed broker and chooses to conduct these operations in-house.

An operator's or user's inventory tracking system (ITS) must be able to account for all merchandise in a zone and provide enough information to make entry for merchandise being removed from the zone. Our experience show that 99 times out of 100, the corporation's existing MRP, bill of materials or internal inventory tracking system(s) are 80-90% complete and sufficient for customs purposes.

Customs, by regulation, accepts: first-in/first-out; foreign-in/first-out; lot-specific; part number; bill of materials; liquid bulk FIFO; serial-number specific; and almost any other inventory tracking system that "protects the Revenue of the U.S." For the 300 operating zones and 350 Subzones of the U.S., there are approximately 650 different ITS and operating systems. Customs also accepts the concept of "work in progress" as a "black box" that they are not allowed to penetrate. This means that if an operator can demonstrate raw material balance, inputs to production, finished product balance and some form of correlation between the three, this is satisfactory for customs.

U.S. customs is currently under specific legal restrictions against divulging company cost, quantity and specification data on imported products. Becoming an FTZ makes your firm no more or less subject to currently gathered and publicly reported trade statistics through the Department of Census, the PIERS network, and other statistical summations. Any applications filed with the FTZ board become public information; however, procedures exist in the regulations to protect sensitive and proprietary information. The protection supersedes the Freedom of Information Act and allows a level of confidentiality which has been acceptable to a large percentage of Fortune 500 companies that currently enjoy FTZ status.

Sources: U.S. Department of Commerce, Foreign-Trade Zones Board; U.S. Customs Service, Part 146 Regulations and FTZ Manual; National Association of Foreign-Trade Zones.

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