U.S. Customs and Border Protection (CBP) has implemented a new benefit for Customs Trade Partnership Against Terrorism (CTPAT) Trade Compliance partners.
Subject to the conditions further described below, U.S. Customs and Border Protection (CBP) has determined that importers who are CTPAT Trade Compliance partners, in good standing, may utilize a Foreign Trade Zone (FTZ) for the storage of goods subject to potential forced labor enforcement action.
In order for importers who are CTPAT Trade Compliance partners to utilize these benefits, they must identify to CBP which FTZ Operator they will use to store these goods and receive Port Director approval prior to the movement of the goods. The FTZ Operator must have an active Type 4 bond, FIRMS Code, and be in compliance with all CBP regulations. The selection of an FTZ Operator by a CTPAT Trade Compliance partner for this purpose is subject to Port Director approval.
Importers that are not CTPAT Trade Compliance partners are not authorized to utilize an FTZ for the storage of goods detained for forced labor. Such importers may only store detained forced labor goods in bonded warehouses using a Type 21 entry.
All importers that are CTPAT Trade Compliance partners and have shipments detained for forced labor which are currently stored in an FTZ may continue to store such shipments in the FTZ if the importer files a formal 06 entry to include all data elements for the suspected goods.
As entities are added to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, any goods that are impacted but are stored in an FTZ at the time of such addition may continue to remain in the FTZ only if the importer files an 06 estimated weekly entry containing all line-item data elements as required for the transaction. Such filings enable CBP to properly evaluate the merchandise being presented for entry.
For the complete message and additional conditions, please see CSMS Message # 62269186
Policy questions concerning this guidance should be directed CSCWarehousing@cbp.dhs.gov. CTPAT importer notifications should be directed to CTPATTradecompliance@cbp.dhs.gov.
Additional question can be directed to the Willson International Transition Team at transitionteamus@willsonintl.com