FTZ’ine March 2026
March 2, 2026
Gold Rush. Without the Rush.
No Foolin’. U.S. Customs and Border Protection said that it’s new IEEPA refund system (called CAPE) is on track to be ready late this month. And it looks like FTZs are included in the first phase of CAPE development.
But don’t expect funds to be disbursed quickly. CBP reported yesterday that refunds will only be issued as entries liquidate, not sooner. And it will take up to 45 days to get entries approved for refunds once submitted to CAPE.
Separately, the Trump Administration announced dozens of investigations into new tariffs that, by July, will replace the Section 122 tariffs that just went into effect.
China has expressed concerns that the new round of investigations will target its exports, rousing a trade giant that had been soothed of late.
The E.U. approved a U.S. trade deal, but not the exact deal the U.S. had agreed to. Thus negotiations will begin again. Section 232 tariffs on goods from European nations could be on the table, as derivative items were added by the U.S. after the E.U. agreement was made. IEEPA, Section 122, and Section 301 will add even more flavor to the talks.
The war with Iran is being fought far from U.S. borders. But the impact has made it to our shores in terms of higher gas prices, higher mortgage rates, and a forecast for rising inflation and lower economic growth.
Don’t shoot the messenger but, um, if you haven’t filed yet, tax day is in two weeks.
Top Story - Foreign-Trade Zones Prepare For Refunds
The U.S. Customs and Border Protection (CBP) reported yesterday that it was making progress coding a streamlined process for refunding some $166B in IEEPA tariffs collected since April of last year. CBP estimated that the new system could take up to 45 days to review and process refund applications.
Late last month, the U.S. Court of International Trade (CIT) issued two Orders specifying that CBP is obliged to provide refunds for all IEEPA duties, including tariffs targeting Brazil and India, and entries whose liquidation is considered final, expanding the scope of potential refunds.
Brandon Lord, CBP’s Executive Director of the Trade Programs Directorate in the Office of Trade filed a report with CIT saying development of a new refund claims portal, review, processing and refund system is now between 60% and 85% complete.
He did not provide a start date for applications, but the agency previously had indicated a 45-day goal, a deadline that ends in late April. The Consolidated Administration and Processing of Entries (CAPE) system, in its Phase 1 configuration, would cover roughly 63% of entries that paid IEEPA tariffs.
More than 330,000 importers paid the IEEPA tariffs on 53 million shipments, according to court documents.
Judge Richard Eaton of the Court of International Trade originally ordered CBP to begin processing refunds using its existing system, but the agency instead proposed a new process that would be ready to accept refund applications as soon as this month and would not require importers to sue.
CBP proposed the CAPE system, which has since been accepted by the judge.
The agency also said it would accept entries liquidated in the previous 80 days and reliquidate by the 90th day. However, liquidated entries and entries for which the liquidation status is ‘final’ will not be included in the Phase 1 release of CAPE.
As previously outlined to CIT, importers will request refunds through a dedicated claims portal as part of a four-step CAPE process. Development of this first stage of the system is 85% complete, according to yesterday’s filing.
Meanwhile, the remaining components are between 60% and 80% complete, marking incremental progress from CBP’s previous update to the Court. The mass processing step of the system remains a bottleneck at 60% complete.
CBP also outlined an expanded list of entries CAPE will accept within its initial rollout. These include those labeled “suspended,” “extended” or “under review,” as well as warehouse withdrawals. The agency said it does not anticipate any delays in development from this expansion. Good news for FTZs.
CBP said it plans to expand CAPE’s capabilities to include finally liquidated, including finally liquidated entries in subsequent phases of development after the system launches.
To prepare for CAPE launch, importers should consider taking the following steps:
• Assemble a list of liquidated and unliquidated entry numbers impacted by IEEPA tariffs
• Authorize Electronic Refunds through the ACE Portal
• Complete any additional steps (TAO account recovery, 5106 upload, etc.) required by the Portal to permit ACH refund authorization.
FTZ Board Expands Staff, But CBP Pay Woes Continue
The Foreign-Trade Zones Board announced yesterday that two new examiners have been added to assist with designation applications. John Frye and Brian Warnes have each been each been assigned to application responsibilities in a single state.
The bulk of site and subzone designation applications are still being handled by just three examiners.
At a later date, those geographic responsibilities would likely be more evenly distributed across five examiners, so Grantees may expect more adjustment in assignments in the coming months.
FTZ Grantees welcomed the news that help was on the way.
There is no help in sight for CBP however.
While much has been made of the lack of pay for TSA Officers, CBP Officers face the exact same pay situation with seemingly little attention from Congress.
President Trump signed an order to pay Transportation Security Administration (TSA) employees after the House failed to approve the Senate spending measure.
"America's air travel system has reached its breaking point," Trump said in the memo authorizing the payments. He added, "I have determined that these circumstances constitute an emergency situation compromising the Nation's security."
While Trump's action could help ease the plight of air travelers, it does little to resolve the DHS shutdown that halted pay and imposed financial hardship on thousands of CBP workers.
The House and Senate ended the week by passing vastly different funding bills, creating a new impasse as lawmakers left Washington for a two-week recess.
The rejection of the Senate deal creates a noticeable rift between House Speaker Johnson and Senate Majority Leader Thune, who have mostly worked in tandem this Congress.
FTZs Pivot To Post-IEEPA Tariff Plan
In response to the Supreme Court ruling striking down IEEPA tariffs, President Trump issued an Executive Order immediately establishing a new, global 10% tariff on import merchandise, with very limited exceptions.
But the legal authority employed to install such tariffs only permits them to be collected for 150 days.
That means new and different tariff regimes will have to be employed this summer if the federal government is going to replace the $175B+ in federal funding lost when the Supreme Court struck down the system of reciprocal and fentanyl tariffs. Thus the end of IEEPA tariffs did not signal a reduction in trade barriers, rather it marked a transition to a broader, more complex tariff landscape for zones.
The Trump Administration has just launched two separate waves of investigation under Section 301 of the Trade Act of 1974. First, major trading partners including China, Japan, India, and Mexico were placed under investigation related to structural excess capacity and manufacturing overproduction. Public comments on this investigation will be collected starting March 17th until April 15th, followed by a hearing on May 5th.
The next day the United States Trade Representative (USTR) announced a separate investigation of 60 countries, representing 99% of all U.S. imports, for failure to block the importation of goods produced with forced labor. USTR is requesting public comments and will hold a hearing on April 28th. Comments and requests to testify must be submitted by April 15th.
The new investigations will bring changes in tariff amounts, stacking regimes, and country coverage. So while the Trump Administration aims to replace revenue lost under the IEEPA ruling, Grantees will find that businesses in their communities may be impacted in different ways than they were under IEEPA.
On top of the myriad potential outcomes of these investigations, several factors further complicate the tariff regimes that foreign-trade zones will need to adapt to this year.
On the 10th of this month, the Court of International Trade will hear a challenge by 23 states regarding the President’s authority to impose Section 122 tariffs. Any change there could force the Trump Administration to look further for ways to replace the lost IEEPA revenue in the federal budget.
The European Parliament voted Thursday to approve a trade deal between the European Union and the United States but with amendments to the original deal.
New language now says that the deal can be suspended if tensions over Greenland re-emerge. Additional tariffs under the new investigations, or an expansion of Section 232 tariffs, could also trigger retaliation from the E.U.
China also warned that the new investigations could upset a trading relationship that had seemed stable as the year began. Li Chenggang, China’s international trade representative, said the Chinese side had expressed serious concern about trade investigations at the end of last month’s high-level talks in Paris.
As USMCA Negotiations Begin, FTZs Wonder If One Agreement Will Survive
Last month the U.S. and Mexico began bilateral talks on updates to the United States Mexico Canada Agreement (USMCA).
International traders wonder if a single agreement with common rules of origin will survive the process.
On March 18th, U.S. Trade Representative Jamieson Greer and Mexican Secretary of Economy Marcelo Ebrard announced the start of bilateral technical meetings. Discussions focused on boosting U.S. and Mexican production and manufacturing employment as well as limiting non-market inputs.
Ambassador Greer noted that Canada is lagging behind on preparatory USMCA negotiations. A Canadian official downplayed concerns and stated that it is “not unusual for bilateral discussions between each party to move at a different pace.”
Even so, the current state of relations with Canada make it plausible that the outcome of the USMCA review will be two independent trade agreements.
Every day more than $4 billion worth of goods cross the United States’ borders with Canada and Mexico: U.S. auto parts headed for car factories in northern Mexico, cartons of Mexican avocados bound for California supermarkets, Canadian aluminum destined to become cans of Pepsi.
Much of this bustling cross-border commerce is duty-free, thanks to USMCA. The United States is demanding changes to the treaty, and Ambassador Greer told Politico in December that President Trump would be willing to pull the United States out of the pact if he can’t get the deal he wants.
American farmers are especially keen to see the deal renewed: Last year, they shipped nearly $31 billion in agricultural products to Mexico and $28 billion to Canada.
U.S. imports from Canada and Mexico were spared from reciprocal and fentanyl tariffs; many goods compliant with USMCA origin rules still enter the United States duty free.
The USMCA did little to ease the U.S. deficit in the trade of goods with Mexico, which rose last year to a record $197 billion as the United States reduced its reliance on Chinese imports. The U.S. also ran a merchandise trade deficit with Canada of $46.4 billion last year, though that was a decrease from 2024.
War Adds To Economic Uncertainty For Foreign-Trade Zones
While geopolitical tensions have long influenced global trade, the concurrent wars in Ukraine and Iran present a complex challenge for FTZ operators, who must now navigate not only tariff volatility but also physical disruptions to supply chains, rising costs, and inflationary pressure.
Foreign-Trade Zones are designed to provide flexibility in global trade—particularly in times of turbulence. However, recent events underscore how vulnerable even optimized supply chains can be.
Attacks on vessels and reduced traffic through the Strait of Hormuz have already begun to disrupt global shipping flows, echoing prior events such as pandemic-era port congestion, Panama Canal restrictions, and Red Sea rerouting.
The U.S. economy was showing some signs of stress before the war, and the February jobs report was disappointing.
As the war has progressed, a new realization began to sink into the consensus forecast: the economic and financial damage of the war is already significant, and many countries have little headroom for significant policy responses.
The Organization for Economic Cooperation and Development (OECD) has said the war in Iran will lead to a surge in inflation this year, as the closure of the Strait of Hormuz pushes up prices for oil, gas and other commodities.
OECD predicts that will result in a 4.2% average inflation rate in the United States this year, more than one percentage point higher than the group’s forecast at the end of last year. Across the Group of 20 nations, inflation is forecast to average 4 percent this year, 1.2 percentage points higher than previously expected.
The global economy is projected to grow by 2.9 percent this year, an unchanged forecast, supported by spending on artificial intelligence.
“The resilience of the global economy is now being tested,” the OECD said. There is a “significant” risk to its projections if there are persistent disruptions to exports from the Middle East.
FTZ Staff Activity
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-108-2026) in FTZ 214H on behalf of Aprinnova LLC, Wilmington/Leland, NC on February 27, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-109-2026) in FTZ 244 on behalf of DP Worle Tech US LLC, Perris, CA on February 27, 2026
- FTZ Board Staff processed a processed a Termination (S-110-2026) in FTZ 244A on behalf of Skechers USA Inc., Moreno Valley/Perris, CA on February 27, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-111-2026) in FTZ 75S on behalf of Rinchem Company LLC, Chandler, AZ on February 27, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-112-2026) in FTZ 22AJ on behalf of Sandvik Mining and Construction Logistics Ltd, Romeoville, IL on March 2, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-113-2026) in FTZ 104 on behalf of RTS Holding LLC dba RoadOne TermodaLogistics, Port Wentworth, GA on March 2, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-114-2026) in FTZ 129F on behalf of ALA Energy LLC, Ferndale, WA on March 3, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-115-2026) in FTZ 18U on behalf of KLA Corporation, Milpitas/Fremont/Newark/San Jose, CA on March 3, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-116-2026) in FTZ 23I on behalf of Foreign Parts Distributors Inc., Miami, FL on March 3, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-117-2026) in FTZ 32 on behalf of Planet Holdings Inc. dba Planet Cellular, Doral, FL on March 3, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-118-2026) in FTZ 32 on behalf of C&L Trading of Miami Inc., Opa-Locka, FL on March 3, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-119-2026) in FTZ 244 on behalf of Hino Motors Manufacturing USA Inc., Mira Loma, CA on March 4, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-120-2026) in FTZ 18 on behalf of Aivres Systems Inc., Fremont, CA on March 4, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-121-2026) in FTZ 50 on behalf of Hongfa America Inc., Lake Forest, CA on March 4, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-122-2026) in FTZ 50 on behalf of Plastic Express, City of Industry, CA on March 4, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-123-2026) in FTZ 281 on behalf of Global USA Corp., Miami, FL on March 5, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-124-2026) in FTZ 196 on behalf of Lennox Industries Inc., Fort Worth, TX on March 5, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-125-2026) in FTZ 241 on behalf of Chauvet & Sons LLC, Davie, FL on March 5, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-126-2026) in FTZ 221 on behalf of MGC Pure Chemicals America Inc., Mesa, AZ on March 5, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-127-2026) in FTZ 50 on behalf of Elite Logistics and Fulfillment LLC, Fontana, CA on March 6, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-128-2026) in FTZ 32J on behalf of Ferrari Express Inc., Miami, FL on March 10, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-129-2026) in FTZ 94 on behalf of Carter Express Inc., Laredo, TX on March 10, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-130-2026) in FTZ 116E on behalf of Golden Pass LNG Terminal LLC, Baytown, TX on March 10, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-131-2026) in FTZ 32 on behalf of Quantum Trade USA Corp, Miami, FL on March 10, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-132-2026) in FTZ 281 on behalf of Del Valle Brands Inc., Hialeah, FL on March 11, 2026
- FTZ Board Staff processed a processed a TSF Subzone subject to the activation limits of the Grantee (S-133-2026) in FTZ 252 on behalf of Fermi Inc. (Power Generation), Panhandle, TX on March 11, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-134-2026) in FTZ 244 on behalf of UNIS LLC, Riverside, CA on March 11, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-135-2026) in FTZ 22 on behalf of GE Precision Healthcare LLC, Carol Stream, IL on March 12, 2026
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-136-2026) in FTZ 244 on behalf of Isuzu North America Corporation, Mira Loma, CA on March 12, 2026
Foreign-Trade Zone Board Activity
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- Aprinnova LLC, submitted a notification of proposed production activity for cosmetic products within Foreign-Trade Zone 214 in Leland, North Carolina. MORE
- Tesla Inc., submitted a notification of proposed production activity for battery storage products and components within Foreign-Trade Zone 18 in Fremont, Livermore, and Lathrop, California. MORE
- Zapp Precision Wire, Inc., submitted a notification of proposed production activity for precision wire and metal products within Foreign-Trade Zone 21 in Summerville, South Carolina. MORE
- Baker Hughes Oilfield Operations, LLC, submitted a notification of proposed production activity for components for electrical submersible pumping systems within Foreign-Trade Zone 53 in Claremore, Oklahoma. MORE
- Air Venturi, Ltd., received authorization of production activity of air guns and pressure tanks within Foreign-Trade Zone 40 in Solon, Ohio. MORE
- Garmin International, Inc., received authorization of production activity of avionics and auto products; marine and personal GPS Products within Foreign-Trade Zone 17 in Olathe, Kansas. MORE
- Molnlycke Health Care, received authorization of production activity of medical dressings and foam within Foreign-Trade Zone 186 in Brunswick, Portland, and Wiscasset, Maine. MORE
- RECARO Aircraft Seating Americas, LLC, received authorization of production activity of aircraft seats within Foreign-Trade Zone 196 in Fort Worth, Texas. MORE
- The Premcor Refining Group, Inc., received authorization of production activity of sustainable aviation fuel within Foreign-Trade Zone 116 in Port Arthur, Texas. MORE
- ZF Transmissions Gray Court LLC, received authorization of production activity of electric and automatic vehicle transmissions within Foreign-Trade Zone 38 in Gray Court and Fountain Inn, South Carolina. MORE
- Patheon API, Inc., submitted a notification of proposed production activity for pharmaceutical products within Foreign-Trade Zone 46 in Cincinnati, Ohio. MORE
- The Premcor Refining Group, submitted a notification of proposed production activity for renewable fuels within Foreign-Trade Zone116 in Port Arthur, Texas. MORE
- Fermi, Inc., submitted an application requesting subzone status for their facility within Foreign-Trade Zone 252 in Panhandle, Texas. MORE
- AuroraTe LLC, submitted a notification of proposed production activity for galvanized steel pipes within Foreign-Trade Zone 84 in Houston, Texas. MORE
- Centrome Inc. dba Advanced Biotech; received approval to operate their Oneonta, New York facility as Foreign-Trade Zone 37I. MORE
- Dongjin Semichem Texas, Inc., submitted an application requesting subzone status for their facility within Foreign-Trade Zone 183 in Killeen, Texas. MORE
- Methods Machine Tools, Inc., submitted an application requesting subzone status for their facility within Foreign-Trade Zone 27 in Acton and Sudbury, Massachusetts. MORE
- Supreme International LLC dba Perry Ellis International, submitted an application requesting subzone status for their facility within Foreign-Trade Zone 104 in Dublin, Georgia. MORE
- Department of Commerce Foreign-Trade Zones Board, published a Site Renumbering Notice for Foreign-Trade Zone 68. MORE
- Hypertherm Inc., submitted a notification of proposed production activity for plasma cutting equipment and components within Foreign-Trade Zone 81 in Hanover and Lebanon, New Hampshire. MORE
- Webco Industries, Inc., submitted a notification of proposed production activity for steel tubing within Foreign-Trade Zone 164 in Kellyville, Oklahoma. MORE
- Stadler US Inc, submitted a notification of proposed production activity for passenger rolling stock within Foreign-Trade Zone 30S in Salt Lake City, Utah. MORE
No Cake And Ice Cream Yet:
It was another month of dynamic trade developments for the foreign-trade zone community. While there is cause for optimism that trade terms will stabilize soon, too much remains unsettled to do any celebrating just yet.
Negotiations with China resulted in a temporary pause in the sky-high rates FTZs had been paying on their imports. But recent rhetoric from Washington suggests the pause won’t last past the 90 days of the agreement. If it even lasts that long.
The U.S. Court of International Trade ruled that the use of IEEPA to place a 10% additional tariff on all imports overstepped presidential authority. The IEEPA tariffs are still being collected until higher courts make a final ruling. The financial stakes are HUGE for both sides.
An investment deal in U.S. Steel prompted the doubling of Section 232 tariffs on imported steel and aluminum beginning this Thursday. Nothing on the table suggests those 50% rates will be reduced anytime soon. Zones need to prepare accordingly.
Foreign-trade zone applications are down. Way down. Staff losses at the Foreign-Trade Zones Board and the loss of the NPF status option appear to be taking their toll. Bonded Warehouse applications? Still overwhelming CBP in certain ports.
