Foreign Trade Zones/Warehouse Working Group Proposes 18 Recommendations to CBP

September 16, 2025 |Customs

To facilitate the flow of information between ACE and foreign-trade zones and bonded warehouses, the foreign trade/warehouse working group with the Commercial Customs Operations Advisory Committee is offering 18 recommendations to CBP ahead of COAC's quarterly meeting on Sept. 17.

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The working group is part of COAC's Secure Trade Lanes subcommittee. The upcoming meeting will be the last COAC meeting in its current iteration, as CBP seeks to restructure COAC to align it with CBP's focus on national security, the protection and promotion of domestic industry, and the closure of “revenue and enforcement gaps” caused by unfair trade practices, according to July 1 communications from the agency to the trade (see 2507010077).

The proposed recommendations are:

To create e214 (Application for Foreign-Trade Zone Admission and/or Status Designation) visibility in ACE web portal reports.
To limit CBP Form 28 inquiry for type 06 entry summaries to one entry summary line.
To create a new CBP Form 216 (Application for Foreign Trade Zone Activity Permit) submission and approval processes in the ACE web portal.
To create CBP Form 349 (Harbor Maintenance Fee Quarterly Summary Report) visibility in the ACE web portal.
To expand the number of HTS lines on the cargo release and entry summary filings beyond the current limitation of 998 lines.
To integrate the PGA data message set into the e214 transaction filing set.
To eliminate the 5-day physical withdrawal requirement outlined in federal regulations governing the release and removal of merchandise from a foreign trade zone (19 CFR 146.71).
To amend the definitions set forth in federal regulations on foreign trade zones (19 CFR 146.01), including all terms defined in 19 CFR Part 146, to more accurately reflect current practices and interpretations.
To create a mechanism in the automated in-bond system so that FTZs and bonded facilities can withdraw merchandise on an IT (Immediate Transportation) for Export.
To carve out an exclusion exception to 19 CFR 146.67(c) and 146.70(c) that permits merchandise withdrawn from an FTZ with any zone status to be transported under an IT (Immediate Transportation), allowing the merchandise to move from port to port with the intention of entering a bonded facility, where it will be exclusively sold for export.
To initiate a focused and collaborative review of 19 CFR Part 19 - Customs Bonded Warehouses.
To develop standardized guidance and training tools to promote consistent application of bonded warehouse procedures across all ports.
To expand the definition of "Feedstocks" in 19 CFR 146.92(b) so that feedstocks means crude petroleum, intermediate product, biological or non-fossil sources used in a petroleum refinery to make a final product.
To expand the definition of "Final Product" in 19 CFR 146.92(d) so that final product means any petroleum or petroleum-like product and petrochemical product produced in a refinery and thereafter removed therefrom or consumed within the zone.
To expand the definition of "Petroleum refinery" in 19 CFR 146.92(f) so that petroleum refinery means a facility that refines petroleum or similar non-bituminous origin feedstock, including renewable or sustainable feedstock in separation, chemical, or similar manufacturing processes to produce petroleum and petrochemical products or goods like petroleum and petrochemical products.
To expand the definition of "Producibility" in 19 CFR 146.92(h) so that producibility means a method of attributing products to feedstocks processed in petroleum refining or similar manufacturing processes in accordance with the Industry Standards of Potential Production set forth in T.D. 66-16 or as modified for additional feedstocks including non-bituminous origin feedstock that undergoes one or more separation, chemical or similar processes to produce petroleum and petrochemical products or goods like petroleum and petrochemical products.
To clarify CBP regulations at Section 146.41(e) by inserting that any zone status (Privileged Foreign, Non-Privileged Foreign or Domestic) may be changed to Zone Restricted status while in the FTZ as Zone Restricted status is considered constructively exported for the purpose of any Customs law (Section 146.44(c)(1)).
To update the CATAIR Post Admission Correction filing capability in the "ACE Foreign Trade Zone Admission (e214)" to allow a status change from any zone status to Zone Restricted by allowing "P" "N" and "D" in the Existing Zone Status field on the FT51 record of the filing.