
FTZ’ine November 2025
November 11, 2025Nickel For Your Thoughts
Well, it used to be a penny.
But we don’t make pennies anymore.
The U.S. ended production of the penny in November. When it was first introduced in 1793, a penny could actually buy something: a biscuit, a candle or a piece of candy. Now pennies will transition to treasured collector’s items.
The government is back in operation, and FTZ Board and FTZ Board Staff actions are once again being issued.
The U.S. trade deficit fell by nearly 24% in August as exports held steady while new tariffs pushed imports lower. Data release was delayed by the shutdown.
The US, Switzerland, and Liechtenstein agreed to cut U.S. tariffs on most Swiss goods to 15% — the same level imposed on the European Union, from 39%. The U.S. ran a $38B trade deficit with Switzerland last year.
Arguments at the Supreme Court began last month as the Court considers the imposition of tariffs under IEEPA. Most early reads of the proceedings point to some form of tariff reversal. Some large importers such as Costco have filed parallel lawsuits in case the Supreme Court decides that refunds are only due to those that took part in legal action. While a decision is possible this month, early next year is more likely.
The FTZ’ine staff hopes all our readers had a great Thanksgiving break.
FTZ Staff Back On Board After Shutdown
The longest government shutdown in U.S. history officially ended after President Trump signed a Continuing Resolution passed by Congress on Wednesday, November 12th.
Some impacts could extend through December, such as national parks trying to make up for lost visitor revenue or taxpayers waiting longer for refunds from a backlogged IRS. We all have just returned to work after 4 days off work. Imagine your inbox after 43 days out of the office.
Things won’t return to business-as-usual at the FTZ Board right away either.
But the work has started. ASF application approvals started moving the same week of the restart, and Federal Register Notices are already posting.
Emails sent to Board staff are acknowledged with a plea for patience as they grind through the backlog of cases.
The news is not as good for manufacturers looking to the FTZ program for help with exports. In addition to requests for answers to a slew of undocumented questions, several production authority requests were not authorized in any form, and others were approved with missing components and products.
D.C. museums and other national sites began a staggered reopening. New loan applications and guarantees for rural properties through the USDA also resumed, with a backlog to be addressed.
At least 670,000 federal employees were furloughed during the shutdown. Those workers were expected to receive back pay from missed paychecks, along with essential workers like air traffic controllers and airport security screeners, who had worked without pay during the shutdown.
Some agencies such as the Department of Agriculture and Veterans Affairs are now funded through the end of the fiscal year. However there's a looming threat of another shutdown in the not-too-distant future, since the rest of the government is only funded through Jan. 30th.


Tech Tip: December Marks Start Of FTZ Data Enforcement By CBP
U.S. Customs and Border Protection announced it will begin enforcement of FTZ data validations on e214 submissions beginning December 11th.
In CSMS # 66789049, CBP reminded filers that it plans to validate the FIRMS Code, Zone ID, and Port of Entry data submitted to ACE in Foreign Trade Zone Admission transactions.
The FIRMS Code cannot be blank, must be on file in CBP system, must refer to an FTZ Site in ‘Active’ status, must be in the Port of Entry, and must be Bonded.
The bond on the FIRMS Code must be ‘Activity Type 4 FTZ’, and must be in ‘Active’ status.
The Zone ID submitted in the FT10 record must match the Zone ID assigned to the FIRMS Code.
The validations are currently available in the ACE Certification (CERT) environment for testing.
FTZ Users and Operators who have an ACE Portal Account view as an FTZ Operator can verify the Zone ID, FIRMS Code, and Port Code information associated with the FTZ Sites which they operate.
Questions about how to prepare for the new CBP validation enforcement? Contact us at info@iscm.co.
LA Ship Fire May Spread FTZ Losses
Henry Hudson could be excused for preferring the Port of New York/New Jersey.
After all, he discovered the port in 1609.
That is still no excuse for his ONE namesake vessel to ignite Berth 218 in the Port of Los Angeles.
The ONE Henry Hudson caught fire on November 21st while moored for unloading at the Port of LA.
The ship had just arrived from Japan, with some cargo destined for U.S. FTZs. Although the fire was successfully extinguished, containers that were not unloaded before the fire was discovered will be delayed, and may be a loss.
By the next afternoon, the blaze was isolated to a single cargo hold, and the vessel had been moved approximately one mile offshore, near Angel’s Gate Lighthouse.
Assistant Chief Carlos Calvillo of the Los Angeles Fire Department (LAFD) explained: “Fire burned on multiple sub-levels below deck in areas that were largely inaccessible, which required a high level of communication and coordination to ensure the safety of personnel and the crew. Remarkably, and thankfully, no injuries have been reported.”
The U.S. Coast Guard established a ½-nautical-mile safety zone around the vessel, directing traffic and staging additional search and rescue resources while assisting with stability and hazardous material assessments.
While the cause of the fire is still being investigated, news reports have suggested that the fire may have been caused by electrical items.
The fire broke out at 6:38 p.m. on November 21st, and by 3:00 a.m. the next day, the vessel had been undocked and moved offshore while crews continued onboard suppression.
LAFD deployed nearly 200 firefighters, including Hazmat units, search and rescue teams, and fire boats.
All hazardous materials, including firefighting water, remain contained on board the vessel, and will be removed and treated once the vessel is rebirthed at the Yusen terminal for unloading.
Salvage contractor DONJON-SMIT, now in temporary possession of the vessel, has flown in specialists to manage marine firefighting and prepare the ship for safe offloading and repair.


Foreign-Trade Zones Wonder What’s Next For IEEPA
In one of the biggest cases of the year, Supreme Court justices are grappling with challenges to President Trump’s reciprocal and fentanyl tariffs. In the short term, the outcome of the case could determine whether the president can continue to rely on a 1977 emergency law to impose tariffs without authorization from Congress. In the longer term, the decision by the court could have profound implications for limits on presidential power.
The justices agreed to hear the case on an expedited schedule. The court typically announces its decisions by the end of June or early July, but a decision in this case could come much sooner because of its impact.
During opening arguments in the case last month, even conservative justices appeared skeptical of the Trump administration’s stance on the tariffs. (more)
“I mean, these are kind of across the board,” Justice Amy Coney Barrett, who is seen as a critical vote, said to Solicitor General D. John Sauer. “And so is it your contention that every country needed to be tariffed because of threats to the defense and industrial base? I mean, Spain? France?”
Chief Justice John G. Roberts Jr., too, queried the administration lawyer about the president’s authority to impose these specific tariffs. The chief justice acknowledged that the tariffs were used “in dealings with foreign powers,” but he added that “the vehicle is imposition of taxes on Americans,” which he noted had “always been the core power of Congress.”
Justice Neil M. Gorsuch pushed Mr. Sauer on whether there would be any guardrails that would prevent Congress from “just abdicating all responsibility to regulate foreign commerce — for that matter, declare war — to the president.”
The justices repeatedly returned to a central question during the oral argument: Are the tariffs a type of tax, or something else?
This is a key point because the challengers argue that the president overstepped his authority by imposing the tariffs. They argue that tariffs are taxes, and they point to clear language in the Constitution that gives Congress the power to tax.
In his opening statement, Neal K. Katyal, the lawyer representing the plaintiffs challenging the IEEPA tariffs, insisted that “tariffs are taxes” and that the measures “take dollars from Americans’ pockets.” He added that the nation’s founders “gave that taxing power to Congress alone” and that Congress has only delegated tariff powers to the executive branch “explicitly, always with real limits.”
Justice Gorsuch said he was concerned that a decision upholding the president’s tariffs could lead to a “one-way ratchet” toward more power in the executive branch and “away from the people’s elected representatives” in Congress.
Mr. Katyal, argued that the government has plenty of other legitimate authorities that allow it to issue tariffs. He also made the point that the language in those tariff statutes is very different from IEEPA, suggesting that when Congress passed it in 1977, lawmakers did not view it as a tariff law.
In striking down the reciprocal tariffs in May, the U.S. Court of International Trade ruled that the president couldn’t use emergency powers to combat trade deficits.
That is partly because Congress had specifically given the White House limited authority to address the problem in another statute: Section 122, also of the Trade Act of 1974. That allows the president to impose tariffs of up to 15% for up to 150 days in response to unbalanced trade. The administration doesn’t even have to conduct an investigation beforehand.
But Section 122 authority has never been used to apply tariffs, and there is some uncertainty about how it would work.
In both of his terms, the President has used of his power under Section 232 of Trade Expansion Act of 1962 to impose tariffs on imports that he deems a threat to national security.
Section 338 of the same law authorizes the president to impose tariffs of up to 50% on imports from countries that have discriminated against U.S. businesses. No investigation is required, and there’s no limit on how long the tariffs can stay in place.
In September, Treasury Secretary Scott Bessent told Reuters that the administration was considering Section 338 as a Plan B if the Supreme Court ruled against Trump’s use of emergency powers tariffs.
Foreign-Trade Zones Watch FDA Ditch CSMS System
The Food and Drug Administration announced that it will no longer use the Customs and Border Protection CSMS system to issue informational messages to the trade.
The agency will now issue these messages directly to subscribers of its own automated notification system.
That means FTZs and other importers with merchandise subject to FDA regulation who want to receive published notifications will need to be subscribed to the new FDA system.
No action is necessary for current subscribers to FDA Import Communications, but the change was effective immediately, so you may be missing important messages if you haven’t already subscribed.
Important updates will also be posted on the FDA's Imports News & Events page.
That page also offers the option to subscribe to the FDA import communications system.


FTZ Staff Activity
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-328-2025) in FTZ 262 on behalf of Belnick, LLC, Olive Branch, MS on September 25, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-329-2025) in FTZ 19B on behalf of CLAAS Omaha, Inc., Omaha, NE on September 25, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-330-2025) in FTZ 241 on behalf of FLYHOPCO LLC dba Bradford Marine, Davie FL on September 29, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-331-2025) in FTZ 53D on behalf of Baker Hughes Oilfield Operations LLC, Claremore, OK on September 30, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-332-2025) in FTZ 202 on behalf of Spektrum Brakes, LLC, Cerritos, CA on September 30, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-333-2025) in FTZ 89 on behalf of Aero Metals Alliance, Inc., Las Vegas, NV on November 17, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-334-2025) in FTZ 93 on behalf of KryoCal, LLC dba Kryosphere, Morrisville, NC on November 14, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-335-2025) in FTZ 70AE on behalf of SOLO World Partners, LLC, Ypsilanti, NC on November 13, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-336-2025) in FTZ 74H on behalf of RPM Warehouse MD, LLC, Sparrows Point, NC on November 14, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-337-2025) in FTZ 74 on behalf of Transoceanic Cable Ship Company LLC, Baltimore, MD on November 18, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-338-2025) in FTZ 102H on behalf of Tight Line Composites, LLC, Earth City, MO on November 17, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-339-2025) in FTZ 74AE on behalf of Eastern Drayage, LLC, Rosedale, NC on November 18, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-340-2025) in FTZ 147 on behalf of Franklin Storage LP, Chambersburg, MD on November 19, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-341-2025) in FTZ 200 on behalf of Sullivan Steel Services, Pennington, MD on November 19, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-342-2025) in FTZ 35P on behalf of Glovis America, Inc., Philadelphia, PA on November 19, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-343-2025) in FTZ 86 on behalf of Auto Warehousing Company, Tacoma, WA on November 20, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-344-2025) in FTZ 64 on behalf of Jacksonville Port Authority, Jacksonville, FL on November 19, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-345-2025) in FTZ 38T on behalf of Rudolph Logistics North America, Inc., Greer, SC on November 20, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-346-2025) in FTZ 32 on behalf of Maxiforce, Inc., Doral, FL on November 20, 2025
- FTZ Board Staff processed a processed a Minor Boundary Modification (S-347-2025) in FTZ 32 on behalf of CIF Group International, Inc., Doral, FL on November 20, 2025
Foreign-Trade Zone Board Activity
-
- SubCom, LLC submitted a notification of proposed production activity for undersea fiber-optic cables and repeaters within Foreign-Trade Zone 81 in Newington, New Hampshire. MORE
- AstraZeneca Pharmaceuticals LP received authorization of limited production activity of pharmaceutical products within Foreign-Trade Zone 177 in Mount Vernon Indiana. MORE
- Eagle Electronics received authorization of limited production activity of cellular modules within Foreign-Trade Zone 40 in Solon, Ohio. MORE
- GPI Beauty, Inc., received authorization of limited production activity of plastic tube sleeves within Foreign-Trade Zone 89 in Las Vegas, Nevada. MORE
- Merck, Sharp and Dohme LLC received authorization of limited production activity of pharmaceutical products for research and development within Foreign-Trade Zone 49 in Rahway, New Jersey. MORE
- Pfizer, Inc. received authorization of limited production activity of pharmaceutical intermediate product within Foreign-Trade Zone 43 in Kalamazoo, Michigan. MORE
- PPL Healthcare dba Piramal Pharma Solutions received authorization of limited production activity of cholesterol medication within Foreign-Trade Zone 49 in Rahway, New Jersey. MORE
- Rincon Power, LLC received authorization of limited production activity of contactors, relays and switches within Foreign-Trade Zone 205 in Carpinteria, California. MORE
- Corteva Agriscience, LLC received authorization of production activity of crop protection products within Foreign-Trade Zone 144 in Valdosta, Georgia. MORE
- Philip Stein Holding, Inc. received authorization of production activity of watches within Foreign-Trade Zone 25 in Pembroke Park, Florida. MORE
- Phillips 66 Co. received authorization of production activity of renewable fuels within Foreign-Trade Zone 149 in Old Ocean, Texas. MORE
- Phillips 66 Co. received authorization of production activity of renewable fuels within Foreign-Trade Zone 49 in Linden, New Jersey. MORE
- Phillips 66 Co. received authorization of production activity of renewable fuels within Foreign-Trade Zone 87 in Lake Charles, Louisiana. MORE
- Rohr, Inc. received authorization of production activity of aircraft products within Foreign-Trade Zone 82 in Foley, Alabama. MORE
- Logitech production activity of audio, visual, and gaming equipment was not authorized within Foreign-Trade Zone 29 in Shepherdsville, Kentucky. MORE
- Logitech production activity of audio, visual, and gaming equipment was not authorized within Foreign-Trade Zone 50 in Ontario, California. MORE
- Coroplast Tape Corp. received approval to operate their Rock Hill, South Carolina facility as Foreign-Trade Zone 38W. MORE
- Elite Logistix, LLC received approval to operate their Rock Hill, South Carolina facility as Foreign-Trade Zone 38V. 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.

