In our June “Briefings”, we brought to your attention two matters offering the opportunity for the submission of public comments to the federal government.  With the deadlines for comments quickly approaching, we want to update you on our efforts and encourage you to consider submitting comments.

• Four U.S. Senators have requested feedback from the trade community regarding Congress’ efforts to update customs laws in the context of trade facilitation and key security programs.  The deadline for comments is Tuesday, July 11.  This request for feedback provides an unexpected opportunity to bring to the attention of Congress the need for improvements to the current Automated Commercial Environment (ACE), without which any improvements to trade facilitation cannot be fully realized.  We have drafted feedback that requests increased funding for ACE, updated ACE programming, and better internal CBP training on ACE, as well as increased funding for CBP Officer staffing.  Our proposed changes would provide immediate operational improvements for the entire importing community.  We encourage all importers to consider submitting comments, which we can review upon request prior to submission. Please contact Marshall Miller with any questions.
• The Foreign-Trade Zones Board has issued proposed revisions to its regulations.  The deadline for the submission of comments is Monday, July 10.  We have thoroughly reviewed the proposed FTZ Board Regulation revisions and provide for your review and consideration a table showing the current provisions, the proposed revisions, and our comments.  Please read our comments carefully, as there are a number of important proposed changes, including FTZ adjacency requirements, zone schedule requirements, and tax-exemption eligibility.  We have included our proposal to exclude from HTSUS Chapter 99 duties merchandise produced in an FTZ and intend to provide further comments to the FTZ Board.  We will provide you with an advance copy when they are completed.  We are currently reviewing comments received by FTZ Grantees, Operators, and Users and encourage all FTZ participants to consider submitting comments, which we can review upon request prior to submission. Please contactMarshall Miller or Bryan Brown with any questions.