FTZ Trade & Tariffs Response Team
- 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
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.
As a follow-up to our message of Friday, March 6, 2026, NAFTZ has been informed by CBP that the ACE system issue causing Type 06 entry summary filings to be rejected when they included non-IEEPA trade remedy tariffs (such as Section 301, Section 232, and similar duties) has been resolved. NAFTZ members reported successful entry summary filings on Friday evening.
CBP has not issued any formal announcement regarding either the cessation of IEEPA tariff collection on Type 06 entry summaries or the system correction that now permits these filings to be accepted. NAFTZ has been advised that CBP does not intend to publish such a notice.
Important questions remain regarding whether U.S. FTZs will be able to recover duties paid as a result of required PF status admissions under IEEPA and the associated loss of inverted tariff benefits on those goods. While NAFTZ evaluates potential engagement with the Administration, and while CBP continues to consider the process and timing for refunding IEEPA tariffs, U.S. FTZ operators should consult trade counsel regarding possible avenues for recovery.
Potential options may include, but are not limited to, filing protests on liquidated entries and pursuing claims in court to recover tariff payments.
NAFTZ will continue engaging with CBP, the Administration, and other appropriate officials regarding these issues and will provide additional updates to the membership as further information becomes available.
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.
Following the U.S. Supreme Court’s February 20, 2026 ruling, and after learning that U.S. FTZs were still being required to report IEEPA tariffs on entry summaries despite the Executive Order directing that collection stop, NAFTZ raised this issue with CBP and other Administration offices and has been working with them to help prevent Type 06 entries from being rejected when those tariffs are not included.
Following those discussions, NAFTZ was informed by Administration officials that, as of 7:00 p.m. Eastern on March 4, CBP had stopped collecting IEEPA tariffs on all U.S. FTZ entry summaries. No formal announcement has been issued by CBP, and NAFTZ has been told that CBP does not intend to issue any notice.
At the same time, NAFTZ has received member reports of entries being rejected and accepted when IEEPA tariffs are not included on Type 06 entry summary filings. We are working to assess those filing patterns and outcomes in order to better understand the intended approach going forward.
NAFTZ has been advised that the decision to stop collecting IEEPA tariffs on U.S. FTZ goods was vetted with the White House, and that it reflects the Administration’s intent to implement this change.
NAFTZ will continue advocating on behalf of the FTZ community to ensure the Supreme Court’s ruling is implemented consistently and that U.S. FTZ operators and users are not required to pay tariffs that have been ruled unlawful.
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Court of International Trade orders U.S. CBP to refund IEEPA tariffs The Court of International Trade (“CIT”) ordered U.S. Customs and Border Protection (“CBP”) today, March 4 to liquidate all unliquidated entries and reliquidate non-final liquidated entries subject to tariffs imposed under the International Emergency Economic Powers Act (“IEEPA”) without regard to the IEEPA tariffs. The CIT also stated that a universal injunction in this case is in fact permissible. A CIT conference on the matter has been scheduled for this Friday and the government is expected to argue it cannot comply with the order. Many anticipate the ruling to be appealed, and refunds not to occur until that process is complete. IEEPA Tariffs & FTZ Processing
NAFTZ continues to actively engage with federal agencies and policymakers regarding the operational impacts affecting U.S. Foreign-Trade Zones following the Supreme Court’s IEEPA decision.
Discussions with key decision-makers are ongoing and we have confirmation the issue is receiving active review. While we do not yet have confirmed operational guidance or system changes to report, we are continuing to press for resolution and clarity as quickly as possible. NAFTZ remains in close contact with the relevant agencies and continues to emphasize the urgency and real-world business impacts facing the FTZ community.
We recognize that many members continue to experience operational challenges and financial exposure as ACE processing requirements are still resulting in the reporting and payment of IEEPA-related tariffs on certain FTZ withdrawals for domestic consumption. We understand the frustration this situation is creating and appreciate the continued communication many of you have shared regarding these impacts. We will provide additional updates as soon as substantive information becomes available. Thank you for your continued engagement and patience as we work through this issue. Please Note: When evaluating any tariff announcements, consult with your trade attorney or advisor to understand how these measures specifically impact your U.S. FTZ operations. |
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NAFTZ continues to actively engage with CBP, the Office of the United States Trade Representative (USTR), and Congressional offices regarding the ongoing FTZ processing impacts following the Supreme Court’s IEEPA decision. Discussions are continuing today. We recognize that many members are still encountering situations where ACE processing and validation rules are resulting in continued reporting and payment of IEEPA-related Chapter 99 duties for certain FTZ withdrawals for domestic consumption. This remains a serious operational and financial concern. Based on member reports and technical review, we believe a key driver is how ACE applies validations for FTZ entries compared to standard consumption entries—particularly where privileged status election and effective dates intersect. Current operational reality: Until formal guidance and/or system updates are issued, it appears that the only way to avoid entry rejections for goods admitted in PF status while the IEEPA tariffs applied is to include the applicable IEEPA tariff Chapter 99 classification(s) on the entry summary for those goods. NAFTZ is actively explaining the challenges associated with continued collection of IEEPA tariffs to members of the administration and advocating that this practice cease, with clear operational direction and corresponding system alignment. We will share substantive updates as soon as they are available. Please Note: When evaluating any tariff announcements, consult with your trade attorney or advisor to understand how these measures specifically impact your U.S. FTZ operations. |
As part of our ongoing outreach and conversations with the appropriate federal agencies following the SCOTUS IEEPA tariffs decision, NAFTZ is gathering structured input from the field regarding current operational impacts related to tariff developments and system processing.
In addition to our engagement with CBP, we have elevated these concerns to senior officials at the Office of the United States Trade Representative (USTR) to underscore the urgency and operational impact across the FTZ community.
We are seeking feedback from operators, users, consultants, and other service providers who are experiencing real-time processing challenges, system behavior issues, or compliance uncertainties.
This brief survey is designed to capture both quantitative data and field observations so we can present a clear, consolidated picture of current conditions as these discussions continue.
Please complete the survey by Sunday at 11:59 p.m. ET: (NAFTZ Members - please see your NAFTZ email for the link to the survey)
We will compile and review results first thing Monday morning as part of our ongoing engagement efforts.
Even if your situation is unique — or still developing — your input is important. It helps ensure we are representing the full scope of real-time conditions.
Thank you for helping us document the operational reality with precision as we continue our engagement efforts in Washington, DC.
We understand that many U.S. FTZ operators are looking for additional direction following the Supreme Court’s IEEPA decision, particularly as you continue managing daily FTZ operations and entry activity.
NAFTZ has elevated the FTZ-specific operational questions identified by our Tariff and Regulatory Response Team directly to CBP and other pertinent agencies. These questions address the real-world issues affecting admissions, withdrawals, PF status, Chapter 99 reporting, refunds, and inventory treatment. At this time, there has been no new federal implementation guidance issued that changes current FTZ procedures.
Our focus remains on ensuring that FTZ operational realities are understood as agencies determine next steps. As soon as we have any new information to share, we will communicate promptly.
Thank you for your continued engagement, and please continue forwarding any additional operational scenarios you believe warrant attention.
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.
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...
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.
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
On Tuesday, June 3, 2025, a Proclamation from President Trump was posted that made changes to the current Section 232 tariffs on imported steel and aluminum articles and various derivatives. (download to read the full update)
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)
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.
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.
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This TRRT update covers a reminder on Steel and Aluminum Tariff Announcements, other CSMS Updates from CBP of note, and Inclusion of Chapter 99 HTS Codes on FTZ Weekly Estimates. |
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Clarification on PF-Status Inventory on Hand at Time of Additional Tariff Effective Date: In response to member questions, NAFTZ has continued to request specific clarification regarding treatment and timing of tariffs related to the PF-status election. |
For U.S. FTZs, it is important to note that the EO related to steel tariffs took a different approach to on-hand inventory in PF status admitted to the FTZ prior to the enactment of the newly announced tariff than other recently issued EOs.
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...
This update includes the latest information regarding 1) Updates from CBP requested by NAFTZ 2) De Minimis Reinstated for China 3) Reciprocal Tariff Announcement 4) Anticipated announcement for Steel and Aluminum.
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
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.
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.
Advocacy News
Advocacy Alert: NAFTZ Backs Bipartisan Bill to Fix USMCA FTZ Disparities
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.
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.
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