Wednesday, August 24, 2016

Max Home, LLC (Upholstered Furniture) FTZ Approved, Subject to Limits

On August 23, 2016 the Foreign Trade Zone Board published in the Federal Register Foreign-Trade Zone (FTZ) 158—Vicksburg/Jackson, Mississippi; Authorization of Limited Production Activity; Max Home, LLC (Upholstered Furniture); Iuka and Fulton, Mississippi.

On March 17, 2016, the Greater Mississippi Foreign-Trade Zone, Inc., grantee of FTZ 158, submitted a notification of proposed production activity to the FTZ Board on behalf of Max Home, LLC, within Subzone 158F, in Iuka and Fulton, Mississippi.

The notification was processed in accordance with the regulations of the FTZ Board (15 CFR part 400), including notice in the Federal Register inviting public comment (81 FR 20617-20618, April 8, 2016). The FTZ Board has determined that further review of part of the proposed activity is warranted at this time. The production activity described in the notification, including indefinite extension of production authority, is authorized on a limited basis, subject to the FTZ Act and the Board's regulations, including Section 400.14, and further subject to a restriction requiring that foreign status upholstery leather (HTSUS 4107.11, 4107.92 and 4107.99) be admitted to the subzone in privileged foreign status (19 CFR 146.41). The activity otherwise remains subject to the restrictions and conditions established under Board Order 1744.

When you operate under Foreign Trade Zone procedures, your company is treated (for purposes of customs duties) like it’s located outside the United States. That can mean that U.S. import duties don’t have to be paid on imported components coming to your factory. If your finished product is ultimately shipped to the U.S. market, you may have the option of paying the finished product duty rate rather than the component duty rate. (Many finished products have lower duty rates – or are duty-free – than their components.) And if you re-export the finished product, you don’t ever pay duties on the component materials. There are other potential savings, too, like avoiding duties on imported materials that become scrap, and possible administrative savings and efficiencies.

What are the benefits?

  • Duty Exemption. No duties on re-exports compared to duty drawback which is a refund of duty paid when the product is later exported.
  • Duty Deferral. Customs duties and federal excise tax deferred on imports.
  • Inverted Tariff. In situations where zone manufacturing results in a finished product that has a lower duty rate than the rates on foreign inputs (inverted tariff), the finished products may be entered at the duty rate that applies to its condition as it leaves the zone — subject to public interest considerations.
  • Logistical Benefits. Companies using Foreign Trade Zone procedures may have access to streamlined customs procedures (e.g. “weekly entry” or “direct delivery”).
  • Other Benefits. Foreign goods and domestic goods held for export are exempt from state/local inventory taxes. Foreign Trade Zone status may also make a site eligible for state/local benefits which are unrelated to the Foreign Trade Zone Act.

Examples of successful Foreign Trade Zone implementation:

Claremont Flock, a textile company in Leominster, Massachusetts, imports textile fiber called “tow” and processes it into another form of textile fiber called “flock.” Claremont was paying 7.5% duty on their imports of tow. We helped Claremont qualify for Foreign Trade Zone procedures. Now they import tow without paying the duty, turn it into flock, and when the flock leaves the factory it is subject to the rate of duty applicable to flock, which is zero. Claremont said in a newspaper article that this will save them $250,000 per year.

Millipore Corporation located in Jaffrey, New Hampshire, manufacturers filters containing the imported material polyvinylidene fluoride. Utilizing Foreign Trade Zone procedures they avoid the 6.5% import duty on polyvinylidene fluoride. On its domestic shipment and exports to NAFTA markets, the company is entitled to elect the duty rate that applies to finished filters, (0 %) and thus save the company significant amounts of money.

Questions? We Can Help

David Trumbull, Agathon Associates, has over twenty years of experience assisting U.S. manufacturing companies to save money through informed use of the U.S. Customs regulations. He has worked with companies to file Foreign Trade Zone applications. David has also testified as an expert witness at the Foreign Trade Zone Board in Washington, DC. He is a Licensed Customs Broker (Lic. No. 30179) and was, from 2007 to 2013, an official advisor on manufacturing trade policy to the administrations of presidents George W. Bush and Barack Obama.

Glenn Page, New England Global Advisors, spent over 30 years with U.S. Customs and Border Protection, (CBP). While assigned to the Portsmouth, NH office of CBP he managed oversight for U.S. Customs of Foreign Trade Zone 81, which included Millipore Corporation and Westinghouse Electric.

Glenn and David recently worked together with Claremont Flock in obtaining and utilizing Foreign Trade Zone procedures.

Glenn can be reached at 603-957-8247 or

David can be reached at 617-237-6008 or

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