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

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

NAFTZ Press Release: Impact of Trade Remedy Tariffs

NAFTZ published this Press Release regarding the impact of recent Executive Orders requiring non-domestic status goods admitted to U.S. FTZs be in Privileged Foreign status, and while this is a reduction of cost mitigation factors companies can use as they maintain or increase manufacturing in the U.S., a wide range of capabilities remain available to U.S. FTZ program participants.

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.

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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!