Foreign Trade Zone Manual Excerpt

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Chapter 7

OPERATOR RECORDKEEPING AND REPORTING RESPONSIBILITIES

7.1 General - Recordkeeping is an important aspect of zone supervision because this
allows Customs to check the representation made in the records against the physical
reality found in merchandise in the zone and against independent records of other
parties, such as Customs, carriers, sellers to the zone, and buyers from the zone. When
audit-inspection supervision was initiated in zones in 1986, Customs ceased to maintain

inventory records in zones, turning responsibility over to zone operators, subject to
Customs compliance reviews, (formerly spot checks) audits, and liquidated damages for
operator failure to properly maintain required records.
7.2 Authority for Operator Recordkeeping - Regulations concerning protection of the
revenue shall be approved by the Secretary of the Treasury. (19 USC 81p). Under this
general authority, regulations have been established in 19 CFR Part 146, requiring zone
operators to maintain certain records and make certain reports, as will be described in
this part of the Manual.
7.3 Authority for Importer Recordkeeping - Any owner, importer, consignee, or agent

thereof who imports or knowingly causes to be imported any merchandise into the United

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States shall make, keep, and render for examination and inspection such records which
(1) pertain to any importation, or the information contained in documents required in
connection with the entry of the merchandise, and (2) are normally kept in the ordinary
course of business.
(19 USC 1508).
This requirement is further described and
interpreted in 19 CFR Part 163.

7.4 Customs Authority to Examine Zone Records - The Port Director may direct a
Customs officer to supervise any transaction or procedure at a zone. Supervision may
be performed through, among other methods, a periodic audit of the operator's records or
a review of recordkeeping in the zone. (19 CFR 146.3(b)). The operator shall permit
representatives of the Board access to the zone. (19 CFR 146.4(b)), and see Section
3.3(c) FTZM). Although Customs laws do not. under certain circumstances, apply in
zones, when merchandise is transferred from a zone to Customs territory or is otherwise

not exempt from Customs laws under the FTZA, importers become subject to the records
inspection requirement of Section 1508 and to the examination of books and witnesses
under Section 1509, Title 19 whether or not the books or records are physically kept in
the zone activated area.
7.5 Foreign-Trade Zone Board Authority to Examine Zone Records - The Board has
authority to inspect the premises, operations and accounts of zone grantees and
operators. (15 CFR 400.11(a)<6}).

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7.6 Accessibility and Retention of Records - Records shall be readily available for
Customs review. (19 CFR 146.4(d), 15 CFR 400.28(a)(7), 400.41). UIN records, open

zone lot records, and zone admission files shall be considered readily available for review
if they are located within the activated area, or close enough to the activated area so as
not to impede, delay, or create confusion during a Customs compliance review (formerly
spot check) or audit. The records should be capable of being produced for Customs
review in the zone within four (4) hours of demand by a Customs officer. Automated
records will be considered readily available if they are accessible through a video

terminal which is located in or close to the activated area, with a capability for printing a
hard copy. Records may be stored in hard copy, electronic tape/diskette/CD ROM media
microfiche or as determined by company procedures.
If the original records were
electronic, they may be maintained in an electronic mode; however, if the original records
were hard copies, they must be maintained as such unless the recordkeeper has utilized
the alternative storage procedures in Part 163, Title 19, CFR (19 CFR 163.5). Closed lot

records need not be retained in or adjacent to the zone, but must be retained within the
area of jurisdiction of the Customs port responsible for supervision of the zone. However,
if closed lot records are retained in or close to the activated area, they should be
segregated from open lot records.

(a) Records Retention Period - The operator shall maintain all records, as defined

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in 19 CFR 163.1, and required under 19 CFR Part 146 pertaining to zone
merchandise for 5 years after the merchandise is removed from the zone. (19
CFR 146.4{d)). In the case of merchandise which has been transferred from a
zone to Customs territory or is otherwise not exempt from the Customs laws,
records pertaining to importation which are required or made under 19 CFR 163.3
shall be kept for 5 years after the date of entry of the merchandise. (19 CFR
163.4(a)). Note that since the five (5) year requirement begins with transfer from
the zone, records must be maintained for longer than five (5) years since an entry
must be traceable back to the related admission.

7.7 Safekeeping of Records and Proprietary Information - The operator is responsible for
safekeeping of records concerning merchandise in a zone. The operator, at its liability,
may allow a zone user to store, safeguard, and otherwise maintain inventory records
pertaining to their own merchandise. (19 CFR 146.4(c)}. Only authorized personnel
should have access to the records concerning zone merchandise.
Operators shall
protect proprietary information in its custody from unauthorized disclosure. (19 CFR
146.4(d)).
Generally, "proprietary information" is confidential trade or business
information which would be exempt from disclosure by the Government under 5 USC
552(b)(4), such as value information on invoices or Customs forms. The disclosure of
confidential information by a Customs officer is punishable by dismissal, suspension, or
other disciplinary action, and if done for a valuable consideration, by criminal prosecution
{19 CFR 103.34(a)).

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7.8 Inventory Control and Recordkeeping System - An operator shall maintain the
inventory control and recordkeeping system of the zone in accordance with the provisions
of 19 CFR Part 146 (19 CFR 113.73(a)(2), 146.4(d)).

An operator shall maintain either

manual or automated inventory control and recordkeeping systems or a combination of
manual and automated systems capable of:
(1)

Accounting

for

all

merchandise,

including

domestic

status

merchandise,

temporarily deposited, admitted, granted a zone status or status changed, stored,

exhibited, manipulated, manufactured, destroyed, transferred and/or removed from
a zone;

(2)

producing

accurate

and

timety

reports

and

documents

as

required

by

regulation;

(3) identifying overages and shortages of merchandise in a zone in sufficient detail
to determine the quantity, description, tariff classification, zone status, and value of
the missing or excess merchandise;

(4) providing all the information necessary to make entry for merchandise being
transferred to the Customs territory including, but not limited to, quantities,
descriptions, values, HTS classification, and status; and,

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(5) providing an audit trail to Customs of Customs forms from admission, through
storage, manipulation, manufacture, destruction, exhibition and or transfer of
merchandise from a zone either by a Customs-approved inventory method, i.e.,
zone lot number {ZLN) or unique identifier number {UIN). {19 CFR 146.21{a)).

The operator may authorize a zone user to maintain its individual inventory control and
recordkeeping system. (19 CFR 146.21(b)(3)). However, the operator remains liable for
complying with all inventory control and recordkeeping requirements of 19 CFR Part 146
including 19 CFR 146.21(c).

(a) Operator's Procedures Manual - The operator shall provide the Port
Director with an English language copy of its written inventory control and
recordkeeping systems procedures manual in accordance with the
requirements of 19 CFR 146.6(b}(4) and 146.21{b). The manual shaH
describe, in detail, the methodology to be used in recording transactions in
the operator's inventory and recordkeeping system. The purpose of the
manual is to facilitate Customs compliance reviews (formerly spot checks)
and audits by explaining how the recordkeeping system works; however,
operators and users are responsible for further explaining their system and

its operation to Customs officials upon request.

The operator shall keep

current its procedures manual and shall submit to the Port Director any
change at the time of its implementation. (19 CFR 146.21(b)(2)).

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(1) Maintenance by Zone User - An operator may authorize a zone
user to maintain its individual inventory control and recordkeeping
system

and

procedures

manual.

An

operator

shall

furnish

Customs a copy of the zone user's procedures manual, including
any subsequent changes.

However,

an operator will remain

responsible to Customs and liable under its bond for supervision,
defects in, or failure of a system. (19 CFR 146.21 (b)(3)).
(2) Significance of Customs Receipt of Manual - The operator's
procedures manual and subsequent changes will be furnished to the
Port Director for information purposes only.

Customs receipt of a

manual does not indicate approval or rejection of a system.

(19 CFR

146.21(b)(4) and see Section 4.7(a)(2) FTZM).
(b) Receipt and Admission to Zone - All merchandise will be recorded in a
receiving report or document using a zone lot number or unique identifier.

All merchandise, except domestic status merchandise for which no permit
for admission

is

required

under 19

CFR

146.43,

will

be traceable or

attributable to a Customs Form 214 and accompanying documentation.

Quantities received will be reconciled to a receiving report or document
such as an invoice with any discrepancy reported to the Port Director.

(19

CFR146.22(a), (b)).

The "unique identifier" specified in 19 CFR Part 146, Subpart B, refers to
the unique numerals, letters, or other characters used to identify a specific
inventory category, including fungible merchandise. It is not to be confused
with the sequential zone admission number of the Customs Form 214 (19
CFR 146.32(a)) which is used to admit all merchandise to a zone, other
than domestic status merchandise for which no permit is required.
(1) Suspense File - Merchandise received without complete Customs
documentation or which is unacceptable to the inventory control and
recordkeeping system will be recorded in an admission suspense
account or record until documentation is complete or the system is

capable of accepting the information, at which time it will be formally
admitted to the zone under 19 CFR 146.32 or 146.40. The receiving

report or document will provide sufficient information to identify the
merchandise and distinguish it from other merchandise.
The
admission suspense account or record will be completely
documented for Customs review to explain the differences noted and

corrections made. (19 CFR 146.22(c)j. The admission suspense file

should not be confused with a temporary deposit due to incomplete
documentation under 19 CFR 146.35.
(See Section 6.5(c)(6)
FTZM).

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(2) Recording into Inventory Record System - Merchandise received
will be accurately recorded in the inventory system records from the
receiving report or document using the zone lot number or unique
identifier number for traceability or attribution. The inventory records
will

state

applicable,

the quantity and
zone

status,

date

and

admitted,

description

cost or value where
of

the

merchandise,

including any part or stock number. (19 CFR 146.22(d)).
(3)

Zone

authorizes

Admission
Customs

Files

-

recognition

The

Customs

of computer

Modernization
records.

In

Act

those

situations where the zone lot records are maintained by use of a
computer, there is no requirement that the operator maintain a hard
copy zone lot file.

Instead the files authorized for a UIN system at

Section 7.8(b)(4) FTZM are permissible.

Except as provided

in

Section 7.8(b)(4) FTZM, upon receipt of merchandise in the zone,
the operator shall open and maintain a zone admission file
containing

a

copy

of the

Customs

Form

214,

the examination

invoice, and all other documentation necessary to account for the

merchandise covered

by each

Customs form

214.

The zone

admission file shall be maintained in sequential order by using the
sequential number assigned to each Customs Form 214 as the file

reference numbers. (19 CFR 146.37(a)(1)).
Under a lot number
inventory system, in the instance where more than one zone lot
number is received under one zone admission number, i.e. Customs

Form 214, the file is still maintained in the same order.
The
packages of merchandise shall be marked with the zone lot number,

so the merchandise can be traced back to a particular Customs
Form 214 that these zone lot numbers were received under.

(19

CFR 146.37(d), see Section 6.9(a){7) and 8.2(a)(1) FTZM).
(4) Authorized Inventory Method - Where a Customs authorized
inventory method other than a zone lot number system (specific

identification of merchandise) is used, e.g. First-in, First-Out (FIFO),
the operator shall maintain a file of all Custom Forms 214 in

sequential order.

(19 CFR 146.37(a)(2)).

If an operator wishes to

identify merchandise using a system other than zone lot or FIFO they
should request approval through the internal advice procedures in 19

CFR 177.11(b}(1)(ii).

The request should state the sources of the

merchandise to be identified and the dutiable status of that
merchandise, as well as describing the zone operation to which the
merchandise is subject.

(5) Temporary Deposit - The operator shall maintain an inventory
and recordkeeping system capable of accounting for all merchandise
temporarily deposited in a zone, whether or not it is later admitted to

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the zone (19 CFR 146.21 (a)(1)}.

Applications for temporary deposit

shall be made on a sequentially numbered Customs Form 214,

clearly annotated "Temporary Deposit in Zone".

(19 CFR 146.35(b);

see Section 6.5(c) FTZM. The unique number shall be distinct in
series, suffix, prefix, or other indicator from those assigned to
merchandise under admittance to a zone.

temporary deposit number.

A file shall be assigned a

The file shall

be closed when the

merchandise is removed from the temporary deposit status.

(6) Direct Delivery - Under 19 CFR 146.39, certain criteria must be
met to allow direct delivery to a zone without prior permit.
(c) Accountability for Zone Merchandise - The operator shall have an inventory
control and recordkeeping system(s) capable of accounting for all merchandise
stored, exhibited, manipulated, manufactured, processed, destroyed, or granted a
zone status change.

(19 CFR 146.21 (a)(1)).

Merchandise admitted to a zone

can be identified by either a zone lot number inventory control method (ZLN) or a
unique identification number inventory method (UIN).
Zone Lot Number (ZLN) - A collection of merchandise maintained under an
inventory control method based on specific identification of merchandise
admitted

to

a

zone

by

lot

number.

Use

of

this

method

requires

maintenance of zone lot records, and physical segregation and marking of

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zone lot numbers.
Unique

Identifier

Number

(UIN)

-

This

inventory

method

controls

merchandise in a zone by cumulative identification or record identity, i.e., by
unique numbers and/or letters that identify merchandise admitted to a zone.

Inventory levels are adjusted on a first in first out (FIFO) basis or foreign
first (FOFI) basis pursuant to generally accepted accounting principles.
Merchandise need not be segregated.

(1) Inventory Records - The inventory records will specify by zone lot
number or unique identifier number:
1. location of merchandise;
2. zone status;

3. cost or value, unless operator's or user's financial records
maintain cost or value and the records are made available for
Customs review;

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4.

beginning

adjustments,

balance,
and

cumulative

current

balance

receipts
on

hand

and
by

removals,
date

and

quantity;
5. destruction of merchandise; and

6. scrap, waste, and by-products. (19 CFR 146.23(b)).
A zone lot number or unique identifier number will be used to identify
and trace merchandise in a zone. (19 CFR 146.23(a)(1)).
(2) Lot Number System (Specific Identification) - Under a zone lot

number system of specific identification for merchandise received

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and admitted to a zone, the zone lot number must be assigned at
admission. A zone operator may choose whatever lot number he
requires.
The zone lot number may be a consecutive number
assigned to the merchandise, it may be the lot number already used
by the company for other purposes, or the sequential number
assigned by the operator to the Customs Form 214 upon admission.
If there is more than one zone lot number assigned to merchandise
placed on a Customs Form 214, the zone admission number should
not be utilized as a zone lot number. In an instance where every
admission of merchandise is only one zone lot, the sequential zone
admission number assigned to the Customs Form 214 may be
utilized as the zone lot number. The zone lot number must be
displayed on the merchandise cartons, boxes, etc.
(19 CFR
146.37(d}); also see Section 6.9(a)(7) FTZM). The merchandise
shall be physically segregated to distinguish one zone lot from
another. Each zone lot number shall be identified in the operator's
inventory recordkeeping system. The zone admission file will be
maintained as described in Section 7.8 FTZM.

When zone lot number merchandise is manipulated by combining
merchandise from different zone lot numbers, a new manufacturing
or finished product lot number will be established in the record to
show, in addition to the information specified in 19 CFR 146.23(b);
and Section 7.8(c)(1) FTZM, the original zone lot numbers from
which the merchandise has been transferred.
EXAMPLE:

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100

Fishing poles admitted under zone lot #860813

100

Fishing reels admitted under zone lot #860814

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Fishing kits (manipulated from zone lot #'s 860813 and
860814).
New finished product lot #860815A must be
traceable back to zone lot numbers 860813 and 860814.

Note:
The zone's Grant of Authority must authorize the
activity taking place in the zone.

(3) Authorized Inventory Method - A zone operator may request,
under the procedures of 19 CFR Part 177, approval from Customs

Headquarters for an authorized inventory method in lieu of the zone
lot number system.
{19 CFR 146.23(a)(2) and 146.37 (a)(2)).
Customs has already approved as inventory methods First-in,
First-Out (FIFO) under CSD 81-62. An operator need not request
approval for his zone of an inventory method already approved for
general use by Customs Headquarters. Aside from this method, the

FTZA specifically authorizes Industry Standards of Potential
Production on a Practical Operating Basis as verified and adopted by
the Secretary of the Treasury (known as producibility) as an
inventory method for feedstocks for petroleum refineries operating in
zones, (19 USC81c(d); See Section 11.6(j) FTZM).

FIFO as approved in CSD 81-62 applies to fungible merchandise, i.e.
merchandise which for commercial purposes is identical and

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interchangeable in all situations. (19 CFR 146.1(b)(12)).

(i) First In First Out (FIFO) - Under the FIFO method, any
merchandise withdrawn from stock is assumed, in accordance
with good business practice, to be withdrawn from the oldest
stock first. In applying FIFO procedures, it is important to note
that each zone admission is considered a layer and the zone
operator is responsible for identifying the appropriate
sequence of transfers from the zone to assure the proper
layer was decremented.
This procedure becomes critical
where different costs or values and/or different zone statuses
are involved in the fungible merchandise. Since fungible
merchandise, is, by definition, commercially interchangeable
in all situations, it should be stored together whenever
practical. Identification shall be maintained in the inventory
control system records, generally, by description and part or
stock number. A history file, reflecting the layers by date of
admission, shall be maintained by the zone operator to
provide the necessary details for Customs
reviews (formerly spot checks) and audits.

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compliance

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(4) Domestic Status Merchandise - The operator shall maintain an
inventory control and recordkeeping system{s) capable of accounting
for all merchandise in the zone, including domestic status

merchandise.
Domestic status merchandise which has lost its
identity as domestic merchandise will be treated as foreign
merchandise in nonprivileged foreign status. It will be considered to
have lost its identity as domestic merchandise if the Port Director
determines that it cannot be identified positively as domestic
merchandise on the basis of an examination of the merchandise or
consideration of any proof that may be submitted by a party in
interest.
Acceptable proof includes, but is not limited to a
recordkeeping system(s). (19 CFR 146.42(c); see Section 5.7(a)(3)
and 5.7(d) FTZM). There is no authority under the FTZA permitting
the substitution in a zone of domestic and imported merchandise,

similar to the authorization found in Section 313(b)(19 USC 1313(b)j
TA relating to drawback.
Merchandise manufactured in a zone
under such conditions is subject to full duty if sent into Customs
territory. (TD 54873(2) and see comment and explanation in CSD
82-152).

Inventory

methods

involving

record

identification

and

attribution, such as FIFO or FOFI, are not substitution as understood
in TD 54873(2) and CSD 82-152.

Products derived in part from domestic status merchandise and in

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part from foreign

status merchandise

may retain their respective

zone statuses when the quantities derived from the merchandise
from which they were manufactured

can

be established through

inventory control and accounting procedures approved by Customs.

(CSD

81-67).

For example,

a

known volume of one liquid

in

domestic status may be mixed with a known volume of another liquid

in

foreign

status

merchandise

and

when

the

retain

its

proportion

identity
of

as

domestic

domestic

and

status
foreign

components of the mixture have been determined by independent
volume measurements of each domestic and foreign component
prior to their being mixed, assuming that it is possible to accurately

calculate the quantity of domestic components in the mixture.

(CSD

82-152).
Physical shortages identified in fungible merchandise consisting of a
combination of foreign and domestic status will be treated as a
shortage of foreign status merchandise unless it can be identified
positively as domestic status merchandise.
(19 CFR 146.42(c)).
Such identification would include any evidence that status has been

properly

maintained

under

Customs Headquarters.

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an

inventory

method

authorized

by

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Importations for which a formal entry would not be required may be
admitted to a zone only in domestic or zone-restricted status after
having been entered into the Customs
payment of duty, as appropriate.
(5)

Petroleum

Refinery

Inventory

territory with or without

Accounting

-

Definition

and

attribution of products to feedstocks for petroleum manufacturing
may be either in accordance with Industry Standards of Potential

Production on a Practical Operating Basis as verified and adopted by
the Secretary of the Treasury (known as producibility) or such other
inventory control method as approved by the Secretary of the
Treasury that protects the revenue. {19 USC 81c(d), 19 CFR Part
146, Subpart H; See Section 11.6Q) FTZM).

(d) Transfer of Merchandise from Zone - All zone status merchandise transferred
from a zone will be accurately recorded within the inventory control and
recordkeeping systems.

The inventory control and recordkeeping systems for

merchandise transfers must have the capability to trace all transfers back to a
zone admission under a Customs authorized inventory method or the zone lot

system. (19 CFR 146.24(a)(1), (2)). This recordkeeping responsibility applies to
the transfer of merchandise which has already been constructively transferred to
Customs territory and entered for consumption, although it is no longer in zone
status. (See Section 9.16(d)(2) FTZM).

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The inventory control and recordkeeping systems must be capable of providing all

information necessary to make entry for transfer of merchandise from the zone
(19 CFR 146.21(a)(4) and 146.24(b}).

(e) Physical Inventory - The operator shall take at least an annual physical
inventory of all merchandise in the zone (unless continuous cycle counts are taken
as part of an on-going inventory control program) with prior notification of the
date(s) given to Customs for any supervision of the inventory deemed necessary.
The operator shall notify the Port Director of any discrepancies in accordance with
19 CFR 146.53, 19 CFR 146.23(c). The physical inventory may, but need not be,
conducted in conjunction with the annual reconciliation report under 19 CFR
146.25. Identification of overages and shortages in the inventory system are
required whether or not they are recorded as an adjustment to inventory. Port
Directors shall query each zone to determine their physical inventory schedule and
to assure that prior notification is given of each inventory.

(f) Annual Reconciliation - The operator shall prepare a reconciliation report within
90 days after the end of the zone/subzone year unless the Port Director authorizes
an

extension for reasonable cause.

The operator shall

retain that annual

reconciliation report for compliance reviews (formerly spot checks) or audit by
Customs and need not furnish it to Customs unless requested. There is no form

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specified for the preparation of the report. The report must contain a description of
merchandise, for each zone lot number or unique identifier number, showing zone
status, quantity on hand at the beginning of the year, cumulative receipts and
transfers (by unit), quantity on hand at the end of the year, and cumulative positive
and negative adjustments (by unit) made during the year. (19 CFR 146.25(a), (b)).
(1) Certification to Customs - The operator shall submit to the Port Director
within 10 working days after the annual reconciliation report is complete, a
letter signed by the operator certifying that the annual reconciliation report
has been prepared, is available for Customs review, and is accurate. The
certification letter must contain the name and street address of the operator,
where the required records are available for Customs review, and the
name, title and telephone number of the person having custody of the
records. Port Directors shall maintain a suspense file to assure that the
certification of the annual reconciliation is timely received from each zone
operator.
Reporting of shortages and overages based on the annual
reconciliation will be made in accordance with 19 CFR 146.53; see Section

10.5 FTZM).

These reports must accompany the certification letter.

(19

CFR146.25(c)).
(g) Annual System Review - The operator shall perform an annual internal review

of the inventory control and recordkeeping system(s) and shall report to the Port
Director any deficiency discovered and corrective action taken, to ensure that the
system meets the requirements of 19 CFR Part 146, Subpart B, (19 CFR 146.26).
(h)

Sanctions

for

Recordkeeping

Violations

-

The

operator

is

subject

to

assessment of liquidated damages by the Port Director for violations of the CR
involving

the

113.73(a)(2).

inventory

control

and

recordkeeping

system(s)

under

19

CFR

In addition, the activated status of the zone may be suspended by

the Port Director for cause

on the

grounds

that the inventory control

and

recordkeeping system is impaired to the point where the identity of merchandise in

zone status has been lost and cannot be reestablished without a suspension of
zone operations. (19 CFR 146.82(a)(8)).
7.9 Zone Admission File Maintenance -

(a) Lot System - If the merchandise is accounted for under specific identification,
and not under another authorized inventory method, the operator shall maintain a
zone admission file containing a copy of Customs Form 214, the examination
invoice, and all other documentation necessary to account for the merchandise
covered by each Customs Form 214. There may be multiple zone lot numbers
received under one Customs Form 214 sequential admission number.
As
previously noted in Section 7.8(b)(3) FTZM, if lot records are maintained in a
computer system, there is no requirement that a zone operator maintain a hard
copy file of each individual zone lot number.

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Instead, files maintained by a

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sequential CF 214 number are permitted.
The zone admission file will be
maintained in sequential order by using the sequential number assigned by the
operator to each
146.37(a)(1)).

In

Customs
those

Form 214 as the reference number.

instances

where

computerized

lot

(19 CFR

records

are

not

maintained, then a zone admission file will be maintained in sequential CF 214
admission number order.

The operator shall give a copy of the examination

invoice to the person making entry to transfer the merchandise covered by the
invoice from the zone upon demand of that person or the Port Director.
146.37(b) and see Section 9.7(a){5) FTZM).
copies of all permits

by Customs to admit, exhibit,

process,

transfer

destroy,

or

zone

(19 CFR

In the zone admission file will be

merchandise,

manipulate,

and

any

manufacture,

other

documents

necessary to account for any change in the condition or quantity of merchandise
while it is in the zone. If a yearly blanket Customs Form 216 has been approved
by Customs, it is not necessary to keep a copy in each file, but maintain it
separately for reference.

Each permit or other document should be recorded in

the inventory and recordkeeping system within two working days after the event
occurs so the file will be current when reviewed by Customs officers.
Zone Admission File Contents - Customs forms and other documents that

may be expected to be maintained in the zone admission file include, but
are not limited to:
USE

FORM NUMBER AND NAME
1.

Deposit in Zone

Customs Form 214, Application for

Admission to zone and selection of zone

Foreign-Trade Zone Admission and/or

status

Designation
Customs Form 6043, Delivery Ticket

Transfer to zone pursuant to permit on
CF214

Customs Form 7512, Transportation

Transfer to zone pursuant to permit on

Entry and Manifest of Goods Subject

CF 214, or direct delivery to zone with

to Customs Inspection and Permit

concurrence of carrier

Manifest Discrepancy Report (MDR)

Quantity discrepancy found before or
upon admission to zone. Free form
letter with supporting documentation
prepared by the carrier or operator

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Customs Form 6423, Notice of

Report of within case damage or

Damage, Shortage, or Sample

shortage found by Customs officer, or

report of sample taken by Customs
officer
Customs Forms 7514, 7512, or 7551

Claim of drawback on merchandise
admitted to zone

BATF Forms 5100.11, 1689,5110.30,

Transfer of alcoholic beverages to zone

1582-A, and 1582-B

without payment of Internal Revenue tax

BATF Form 5200.14

Transfer of tobacco products to zone
without payment of internal Revenue tax

2. Operational Activities
Customs Form 216, Foreign-Trade

Exhibition, manipulation, manufacture,

Zone Activity Permit

processing, or destruction of zone
merchandise; temporary removal and

return of zone merchandise
Customs Form 214 or Customs Form

Report overage found in zone

7501

Customs Form 7501, or Manifest

Report shortages found in zone

Discrepancy Report (MDR)
Operator's form or written statement

Used for reporting shortages of less

than 1% and/or $100.00 in duty
Customs Form 214

Request for zone status change for
goods in zone

Customs Forms 4315, Application for

Report of merchandise lost through

Allowance in Duties

casualty or other qualifying causes

Customs Form 5955A, Notice of

Default involving merchandise

Penalty or Liquidated Damages

Incurred and Demand for Payment
3.Transfers from Zone

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Entry for consumption

Customs Form 3461/Estimated
Customs Form 3461 (Immediate
Delivery)
Customs Form 7501, Entry Summary

Entry for consumption

Customs Form 7501, Entry Summary

"Live" entry for consumption

consumption
Informal Entry

Customs Form 368, or 368A

Customs Form 7512, Estimated

Entry for transportation, exportation,

Customs Form 7512 Transportation

transportation and exportation, or vessel

Entry and Manifest of Goods Subject
to Customs Inspection and Permit

or aircraft supply and certain other
goods

Customs Form 5125, Application for
Withdrawal of Bonded Stores for

Entry for supplies for fishing vessels

Fishing Vessels and Certificate of Use

Customs Form 6043, Delivery Ticket,

Removal for transfer to another zone, or

Customs 7512

transfer to a bonded warehouse, or
dock or airport for vessel or aircraft

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supply or for exportation

Customs Form 216, Foreign-trade

Temporary removal and return of zone

zone Activity Permit

merchandise; removal of zone status
merchandise for which no entry is
required

(b) UIN or Other Customs Authorized Systems - In a UIN or other Customs
Authorized inventory system, the zone admission file consists of the CF214
Application for Foreign-Trade Zone Admission and/or Designation and supporting
documentation. The zone admission file will be maintained in a sequential order
based on the zone admission number. Documentation related to other zone

activities and/or removal of the merchandise is kept as part of the inventory control
system(s) and need not be kept in the zone admission file. (19 CFR 146.37

7.10 Transfer of Merchandise History to Another Zone - When merchandise is transferred
from one zone to another, including a zone at the same Customs port, the operator of the

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transferring zone shall provide the operator of the destination zone with the documented

history of the merchandise being transferred.

The documentation to be forwarded is set

forth

in

in

19

CFR

146.66(c)

and

described

Section

9.11(b)

FTZM

and

may

be

transmitted by electronic means.

7.11 Record of Foreign-Trade Zone Activity Under Customs Permit - The operator shall
record on

Customs

Form 216 the

results of an approved

manipulation,

processing,

manufacture, exhibition, temporary removal or certification of destruction, other than by a
blanket

application,

unless

the

Port

Director

chooses

to

physically

supervise

the

operation. {19 CFR 146.52(d), (e); see Section 8.3(d) and 8.4(e) FTZM).
(a) Blanket Application - The operator shall maintain a record of an approved

manipulation, manufacture, process, exhibition or certification of destruction in its
inventory control and recordkeeping system so as to provide an accounting and

audit trail of the merchandise through the approved operation.

A temporary

removal from a zone must be reported on an individual Customs Form 216 unless
otherwise approved by Customs.

(19 CFR 146.52(d)(2)).

7.12 Reporting of Merchandise Discrepancies - Discrepancies in the quantity or condition

of merchandise admitted to, within, or transferred from the zone shall be reported by the
operator to the Port Director as provided in 19 CFR 146.37(c), 146.53(a), and 146.71(b).

See Sections 10.4 through 10.6 FTZM.

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7.13 Grantee Responsibilities - The grantee has certain recordkeeping and reporting
responsibilities under the FTZA, FTZR, and instructions of the Executive Secretary.

(a) Accounts and Records - The form and manner of keeping accounts on each
zone shall be prescribed by the Board.
maintain

their accounts

in

accordance

(19 USC 81p).
with

generally

Zone grantees shall

accepted

principles of

accounting, and in compliance with any requirements of Federal, State, or local
governmental agencies having appropriate jurisdiction over the grantee.

(15 CFR

400.46).
(b) Annual Reports - Each grantee shall make available to the Board annually, and
at such other times as the Board may prescribe, reports containing a full statement
of the operations, receipts, expenditures, and such other information as the Board
may prescribe.

(19 USC 81 p(b); 15 CFR400.46 (d)).

(c) Operator Responsibilities to Grantee - The operator is responsible for
maintaining records and making reports to the extent provided for in the operating
agreement between the operator and the grantee.

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