Manufacturing

CBP determines what constitutes manufacturing on a case-by-case basis, distinguishing it from other operations such as manipulation, processing, production and blending. The U.S. Foreign-Trade Zones Board has defined “Production” as any process that results in (1) a substantial transformation resulting in a change in the essential character of the merchandise, whether or not there is a change in the HTSUS classification (2) a change in the HTSUS classification, or (3) a change in the eligibility for entry of the merchandise. Production activity with foreign status merchandise requires prior approval from the FTZ Board.