FTZ Trade & Tariffs Response Team

NAFTZ has created the Trade and Tariffs Rapid Response Team (TRRT), a cross-functional group focused on efficiently addressing trade and tariff developments. TRRT keeps members informed and supports advocacy efforts for FTZ stakeholders.

TRRT Goals:

Monitor Developments: Track Customs, tariff policy, and regulatory changes.
Assess Impact: Evaluate risks and effects on the FTZ program.
Consult Experts: Bring in external insights when needed.
Enable Action: Provide a rapid, organized response to developments.
Find Solutions: Explore strategies to mitigate tariff impacts.

Click to see the list of NAFTZ members that make up the Trade & Tariffs Response Team.

TRRT Updates

Advocacy Alert: NAFTZ Backs Bipartisan Bill to Fix USMCA FTZ Disparities - December 17, 2025

Today (Dec. 17, 2025), NAFTZ endorsed the bipartisan Foreign-Trade Zone Export Enhancement Act of 2025, legislation that would address a longstanding imbalance under the U.S.-Mexico-Canada Agreement (USMCA) that disadvantages manufacturers operating in U.S. Foreign-Trade Zones.

Under current USMCA rules, U.S. FTZ manufacturers must pay duties on imported inputs before exporting finished goods to Canada or Mexico—even when those goods otherwise qualify for USMCA preferential treatment. Meanwhile, Canadian and Mexican producers benefit from national duty-relief programs that eliminate these costs. NAFTZ has raised these concerns for many years—dating back to the NAFTA era—and has consistently engaged Congress and federal agencies to seek a practical solution. This legislation reflects that sustained advocacy and would help restore parity by allowing the use of Chapter 98 duty-relief treatment for certain FTZ-produced or condition-changed goods. Read the full press release about this bill and NAFTZ's endorsement here.

Call to Action
If you are impacted by this trade agreement disparity, we need to hear from you. You may be manufacturing in a U.S. FTZ and experiencing a cost disadvantage when you export to Mexico or Canada. Or perhaps manufacturing opportunities in your community were lost because the FTZ program did not offer the tariff relief needed to make U.S. production competitive with locating in Mexico or Canada.

If so, please contact Melissa Irmen, NAFTZ Director of Advocacy and Strategic Relations, at mirmen@naftz.org to share your experience and get involved in our efforts to correct this disparity and strengthen U.S. manufacturing.

NAFTZ Testimony before USTR's USMCA Review Hearing - December 10, 2025

On the Friday, December 5, NAFTZ’s Director of Advocacy and Strategic Relations, Melissa Irmen testified before agency representatives about the disadvantage USMCA’s duty referral restrictions puts on U.S. FTZ manufacturers.

These duty referral restrictions, a legacy carried over from NAFTZ, require U.S. manufacturers producing in U.S. Foreign Trade Zones to pay duties to the U.S. government on exported products to Canada and Mexico, whereas Mexican and Canadian counterparts do not have pay similar duties to their countries before exporting to the United States. In fact, U.S. FTZ manufacturers can export duty-free to any other country in the world except for Canada and Mexico. A change to USCMA would end this disparity to U.S. FTZ manufacturers and level the playing field between the U.S. and its neighbors. Read the full summary of this testimony, the entire testimony presented, and NAFTZ's written comments here...

Government Shutdown and Re-Opening: What it means for FTZ Deadlines - November 29, 2025

FTZ Board Update: Impacts from the Recent Government Shutdown

Wednesday, November 19, 2025

NAFTZ has been in communication with the FTZ Board staff, and shared questions and challenges related to case processing. The FTZ Board and staff are working to move past the delay created by the government shutdown and want to assure everyone that all emails that were submitted during the shutdown will be reviewed. The FTZ Board staff are working through submissions in the order received but did see a high volume of emails come in while they were out of the office. There may be a delay from their normal response time as they work through the emails ask that we please do not resubmit any emails or documents that were sent during the shutdown.

If you have a pending request with the FTZ staff or Board, please be aware that case deadlines are being extended by 47 days following the guidance in the linked memo. Any specific questions can be directed to the FTZ Board staff, if not already submitted.

Please Note: When evaluating tariff announcements, carefully review each Executive Order, the corresponding Federal Register Notices, and CSMS messages in detail. Consult with your trade attorney or advisor to understand how these measures specifically impact your U.S. FTZ operations.

FTZ Operational Reminders - July 22nd, 2025

As we approach August 1 and the potential date of reciprocal tariff increases, the Trade and Tariff Rapid Response Team (TRRT) shares a few points to keep in mind while operating a U.S. FTZ. Topics in this update include:

Chapter 99 Numbers on Weekly Estimated Entry (3461) filing
Zone to Zone Transfers
Rules of Transferring between Bonded Warehouses and U.S. FTZs
PGA Considerations

Click here to download the July 22nd update.

Steel and Aluminum Tariffs Increased, and FTZ Inventory Impacted - June 4th, 2025

CIT Rules Against Administration's Imposition of IEEPA Tariffs - May 29th, 2025

In a unanimous decision issued on May 28, 2025, a three-judge panel on the Court of International Trade (CIT) said that President Trump’s use of the International Emergency Economic Powers Act (IEEPA) to impose tariffs exceeded “any authority granted.” The CIT ordered that within 10 calendar days, necessary administrative orders be issued to effectuate the permanent injunction of the orders declared to be invalid as contrary to law, which include... (download to read the full update)

Click here to download the May 29th Update.

New Tariffs FAQ - May 8th, 2025

This Frequently Asked Questions (FAQ) document was developed to address recurring inquiries related to tariffs, as identified through recent NAFTZ member meetings and near daily email inquiries from members. This FAQ incorporates questions raised during the April 10 Fireside Chat and the April 28 on-line discussion with manufacturing members. The content was prepared with support from the TRRT team and NAFTZ staff.

Click here to download the May 8th FAQ.

Questions submitted to CBP following April 2nd Executive Orders - April 3rd, 2025

As the NAFTZ Trade & Tariff Rapid Response Team continues to review the Executive Orders of April 2nd, we have sent an initial set of questions for CBP.

Based on past IEEPA tariffs, we think goods admitted in PF status prior to April 5 have the rate in effect on the admission date locked, but the wording of this EO was slightly different from the previous EO. So, we are confirming. We do not know when to expect an answer as CBP usually waits until the FRN and CSMS are published to respond. However, we wanted to inform the membership that these questions have been formally submitted.

Click here to read the April 3rd, 2025 TRRT update.

Reminder on Steel and Aluminum Tariffs, IEEPA CSMS Messages, and Filing Weekly Estimates - March 11th, 2025

Clarification on PF-Status Inventory on Hand at Time of Additional Tariff Effective Date - February 28th, 2025

Steel and Aluminum Tariffs - February 13th, 2025

Clarification on PF-Status Lock and In-Transit Exemption - February 11th, 2025

As we noted earlier, last week NAFTZ requested guidance from CBP on behalf of its members for pending questions regarding treatment and timing of the in-transit exemption and tariff treatment related to the PF-status election.

Specifically, NAFTZ sought confirmation of its legal interpretation that PF status election locks in the regular and Chapter 99 HTS code(s) and their duty rates in effect at the time of PF-status election...

Click here to read the February 11th, TRRT update.

Various Updates - February 10th, 2025

Executive Orders Levying Tariffs on Mexico, Canada and China Origin Goods - February 2nd & 3rd, 2025

February 2nd Update: The White House announced several tariff actions on Saturday, February 1, 2025, with effective dates of February 4th. The tariffs include an additional 25% on goods with a country of origin of Mexico, 10% on goods with a COO of China, and 25% on goods originating in Canada, with energy and energy resources as an exception with only an additional 10% tariff. NAFTZs TRRT gives considerations for managing inventory on-hand in and destined for U.S. FTZs here.

We encourage members to consult the full text of the memorandum for detailed information and to stay informed about the ongoing reviews and reports referenced in the document. The TRRT will continue monitoring these developments closely, with a focus on their potential impact on FTZ operations.

February 3rd Update: The TRRT has been closely monitoring the latest tariff developments and has updates in the following:

PF Treatment of On-Hand FTZ Inventory
5-Day Rule and Nonprocessing Stipulations
Mexico Tariffs Paused for 1 Month
Canada Tariffs Paused for 1 Month

To see the February 3rd TRRT update, click here.

America First Trade Policy Memorandum

The memorandum outlines an extensive range of investigations, reviews, and actions to be undertaken by various federal agencies. The TRRT has summarized the memorandum’s key provisions and responsibilities. To see the TRRT summary click here.

Advocacy News

Advocacy Alert: NAFTZ Backs Bipartisan Bill to Fix USMCA FTZ Disparities

NAFTZ recently endorsed the bipartisan Foreign-Trade Zone Export Enhancement Act of 2025, legislation that would address a longstanding imbalance under the U.S.-Mexico-Canada Agreement (USMCA) that disadvantages manufacturers operating in U.S. Foreign-Trade Zones.

Read the full release here >>>

Sign-On Letters

Request for Comments Concerning Proposed Modification of Action Pursuant to the Section 301 Investigation of China's Targeting of the Maritime, Logistics, and Shipbuilding Sectors for Dominance

July 7, 2025

NAFTZ and peer associations are urging the USTR to reconsider its proposed actions under Section 301 and instead evaluate the true needs to support the revitalization of domestic shipbuilding.

Read More

In-Transit Provision and Relay Vessels

June 27, 2025

NAFTZ joined a sign-on letter with several other associations to address ongoing challenges surrounding the interpretation of the "in-transit" exclusion.

Read More

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Other Advocacy News

Proposed Changes to Census Reporting for Exports out of U.S. Foreign-Trade Zones - POSTPONED! NAFTZ TRRT Update

New Year, New Proposed Rules for Comment!