With all the discussions about tariffs these days, it can be easy to forget there are other aspects of U.S. importing. This is a good time to check on all of the topics on the radar for NAFTZ advocacy.

Proposed Changes to de minimis:

During the month of January, CBP issued two separate NPRMs addressing the data collection for goods entered under the de minimis rule and making certain products ineligible for the de minimis duty exemption for certain low-value shipments entering the U.S.  Those NPRMs can be found here and here.  The NAFTZ Distribution Advocacy Work Group, chaired by Dallas Hobgood of Kontoor Brands, prepared comments for both notices, reiterating the value that U.S. FTZs could bring to the low-value shipment supply chain if given access to de minimis entry.  The comments submitted by NAFTZ can be found here  and here.

Value of the FTZ Annual Reconciliation Requirement:

Also during January, CBP issued a Federal Register Notice (FRN) asking for comments about the process of performing system reconciliation and providing a yearly letter attesting to having done the reconciliation and its availability for CBP review.  This is part of the annual Office of Management and Budget (OMB) process under the paperwork reductions Act of 1995.  NAFTZ took the opportunity to comment that the yearly letter is, in fact, not a value-add to CBP or the trade.  It is a small thing, but in an era of government efficiency, it was important to point out the ineffectual nature of this requirement.  You can read the comments here.

And We Didn’t Forget About Tariffs:

In anticipation of possible impact of reciprocal tariff approaches to U.S. FTZs, NAFTZ drafted this letter to the General Counsel in the Office of USTR asking for a meeting to discuss such impacts.  In the letter, NAFTZ points out that products manufactured in U.S. FTZs should not be subject to the tariffs and that loss of the tariff inversion benefit would be a large, unanticipated cost to U.S. manufacturing.  NAFTZ continues to advocate these messages to the Administration through multiple avenues.

If you have an impact story we can share to help articulate the point, please let us know.  You can share your story with our Director of Advocacy, Melissa Irmen, at mirmen@naftz.org.