U.S. Foreign-Trade Zone Services

The firm has participated, over the past forty-seven (47) years, in the development of over 800 foreign-trade zone projects in the United States, including Puerto Rico.  We have a highly professional and proficient team devoted to foreign-trade zone development.  Our firm has structured more zone projects over an extended period of time than all other FTZ experts combined. 

In considering foreign-trade zone use, it is important to first determine there is a sufficient financial savings for the zone procedures that outweighs the effort and cost to manage a zone. Second, it is critical to carefully consider a company’s capacity to effectively manage the necessary inventory control requirements.  If a decision is made to move forward, we can assist in all aspects of securing the necessary approvals from the Foreign-Trade Zones Board, local U.S. Customs and Border Protection, and other government agencies.  Additionally, we have the expertise to provide technical training and ongoing assistance and support for zone operations.  We are the only firm that provides detailed two-day bi-annual/annual training sessions for our clients at no charge.

Legal services provided include:

  • Preparation of an FTZ feasibility analysis.

  • Foreign-Trade Zones Board Applications, including the preparation, development, enhancement, review and/or assistance with:

    • Foreign-Trade Zone Application

    • Subzone Application

    • Production Notifications

    • Production Applications

    • Alternative Site Framework

    • Usage-Driven Site Applications

    • Temporary/Interim Manufacturing Request

    • Fast-Track Manufacturing Request

    • Request for Scope Determination

    • Boundary Modification

    • General-Purpose Zone/Subzone Expansion/Reorganization

    • Sourcing Change Notification

  • U.S. Customs Approval of Activation including the preparation, development, enhancement, review and/or assistance with:

    • Application for Activation

    • FTZ Operations Manual

    • Securing FTZ Operator’s Bond

    • Structuring System for FTZ Inventory Management

    • Detailed FTZ System Design (FTZ User’s modification of their software to manage FTZ)

    • Third-Party Software Provider (Selection of and Interaction in mapping and organization development (if applicable))

  • FTZ Training for Operators and Grantees (Startup and Ongoing Basis).

  • Grantee Compliance Package for Zone Grantees including the preparation, development, enhancement, review, and/or assistance with:

    • Seminar on Legal Requirements

    • Zone Schedule (Development or enhancement)

    • Zone Agreements

    • FTZ Board Annual Reports

    • FTZ Marketing Plan

    • FTZ Marketing Materials

    • FTZ Activation Packet for Prospective Operators

    • Legal/Technical Expertise on an Ongoing Basis

    • Comprehensive Set of Zone Contracts for General-Purpose Zone Operators/Subzone Operators/Property Owners

  • Development of detailed self-audit documents and on-site audits of zone projects. 

The firm has developed an automated collection of necessary legal and procedural requirements and documentation for all aspects of zone activities (Foreign-Trade Zone Applications, Management Systems, Operations Manuals, Zone Schedules, etc.).  The firm maintains an exclusive compilation of all Customs Headquarters Rulings, Directives and FTZ Manuals issued on the Foreign-Trade Zone program.  Indexed copies of all Federal Register FTZ Board Application Filing Notices, FTZ Board Orders, and FTZ Board Annual Reports are also maintained in our firm library. 

The firm publishes its monthly Briefings newsletter identifying key developments and linking the summaries to essential documents.  Information is posted to the firm’s website at www.millerco.com on a daily basis to keep our clients up to date on the latest developments in the foreign-trade zone and import/export areas.