# U.S. Foreign-Trade Zones: Current Issues

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## Record

- **Collection:** Congressional research report
- **Document type:** CRS Report
- **Published:** July 28, 1999
- **Citation:** RL30268

## Text

Order Code RL30268

CRS Report for Congress
Received through the CRS Web

U.S. Foreign-Trade Zones: Current Issues

July 28, 1999

Mary Jane Bolle
Specialist in International Trade
Foreign Affairs, Defense, and Trade Division

Congressional Research Service ˜ The Library of Congress

ABSTRACT
This report provides an overview of the U.S. foreign-trade zone system which has evolved
under the U.S. Foreign-Trade Zones Act of 1934 [P.L. 73-397, 19 U.S.C. 81(a)-81(u)]. The
report covers what zones are and how they function, the history of the U.S. zone system, how
the zone system has evolved from its original intent, and policy issues and legislative issues
relating to zones. Twelve tables and figures provide a list of zones and subzones by state, and
information on zone or subzone application, cost savings available to zone users, winners and
losers from zone use, and major zone legislation in the 105th and 106th Congresses. While this
report mentions specific bills, it is not intended as a bill-tracking device. It will be updated
periodically, as needed.

U.S. Foreign-Trade Zones: Current Issues
Summary
Foreign-trade zones are the U.S. version of free trade zones scattered around
the world. Free trade zones are geographic areas which primarily facilitate economic
development, and co-production — the joint production of a single good through the
efforts of workers in two or more countries. All zones are geographic areas which
are physically located inside the boundaries of the country, but treated as if they were
located outside the country for customs purposes. Thus, for goods or materials which
are imported, processed, and later re-exported, no tariffs are payable and customs
procedures are streamlined.
The 235 U.S. zones are among nearly 850 zones world-wide, but differ from
them in two major ways. First, two-thirds of the world’s zones are in developing
countries, producing primarily for export, while U.S. zones produce primarily for
import. Second, whereas many foreign zones are exempt from customs oversight,
taxes, and regulations, U.S. zones are subject to customs control as well as most other
federal, state and local laws and taxes.
Most goods enter the United States through customs at the port of entry, and
then travel to their ultimate destination. Imports which are not yet complete, needed,
or allowed to enter the United States (for quota reasons, for example) after being
unloaded at ports of entry, may be taken to a nearby foreign-trade general purpose
zone (for warehousing or further processing) or to a special purpose subzone (a
manufacturing site which is separate from but linked to a zone.)
The system of U.S. foreign-trade zones has evolved greatly over its 65-year
history since it was set up by the U.S. Foreign-Trade Zones (FTZ) Act in 1934 [P.L.
73-397, 19 U.S.C. 81(a)-81(u)]. Envisioned by some as an engine of export growth,
it has become largely a system for avoiding inverted tariff structures on imports
(higher duties on components than on finished products.)
Policy questions relating to zones today are similar to those of a decade ago;
however, the answers are different, largely because of the evolution of the U.S. and
world economies. Issues today are: Is the Act fulfilling its original intent? (No. The
intent has evolved.) Have U.S. foreign-trade zones helped or hurt U.S. workers?
(The question has been eclipsed by the perceived effects of NAFTA and other trade
influences). Do U.S. foreign-trade zones set U.S. trade policy by circumventing
Congress and U.S. trade negotiators?” (Perhaps, but the issue has dimmed as tariffs
and trade barriers decline, and since new regulations went into effect in 1991.)
Legislative issues pertaining to zones have moved from the macro to the micro
level. P.L. 106-36 (S. Report 106-2), approved June 25, 1999, provides that
commercial importation data for foreign-trade zones shall be included under the
National Customs Automation Program under construction. In addition, H.R. 975
(H.Report 106-52), which passed the House on March 17, 1999, provides for a
reduction in the volume of steel imports, and requires a steel notification certificate
for any steel entering through a foreign-trade zone. Other bills, instead of being
focused on how zones affect the U.S. economy, are now focused more on whether
zone policy should be used to help specific industries and specific localities.

Contents
U.S. Zones in a World Context . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Characteristics of U.S. Zones . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
What Is An Inverted Tariff Structure? . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
How To Achieve Zone Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
How Did the U.S. FTZ Program Begin? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Changes to the Foreign-Trade Zones Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
1980s: The Zone System Began Expanding Rapidly . . . . . . . . . . . . . . . . . . . . . . 7
Congressional Oversight of Zone Growth . . . . . . . . . . . . . . . . . . . . . . . . . 8
The Zone System Today . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Zones Today are Functionally Import Rather Than Export Zones . . . . . . . 12
Zones Today are Primarily “Domestic-Trade” Rather than
“Foreign-Trade” Zones . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Industry Concentrations in Zones Have Changed . . . . . . . . . . . . . . . . . . . 13
The Future of Zones . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Policy Issues Relating to Zones . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Is the Congressional Intent of the Foreign-Trade Zones Program
Being Met? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Have Foreign-Trade Zones Helped or Hurt U.S. Businesses and
Workers? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
Does the Zone System Set U.S. Trade Policy by Circumventing
Congress and U.S. Trade Negotiators? . . . . . . . . . . . . . . . . . . . . . . . 18
Legislation Relating to Zones . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Technical Corrections Relating to Zones . . . . . . . . . . . . . . . . . . . . . . . . . 19
Legislation to Achieve Trade Objectives for Specific Industries . . . . . . . . 19
Legislation to Assist Zone Expansion or Promote Economic
Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Appendix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

List of Figures
Figure 1. Growth in Number of and Employment in Zones, 1978-1997 . . . . . . 8
Figure 2. Concentrations of U.S. Foreign-Trade Zones and Subzones
Among States . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Figure 3. Extent to Which Imports Entering Zones are Subsequently
Exported 1978-1997 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
Figure 4. Extent to Which Zone Exports are Consumed Domestically,
or Exported 1978-1997 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
Figure 5. Source of Zone Inputs (Domestic or Foreign)
1978-1997 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Figure 6. Industry Concentrations of Imports into Zones,
1984 and 1997 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Tables
Table 1. Possible Cost Savings Available to U.S. Foreign-Trade Zone Users . . 4
Table 2. Potential Winners and Losers from Zone Use . . . . . . . . . . . . . . . . . . 17
Table 3. Major Zone Legislation in the 105th and 106th Congresses . . . . . . . . . 21
Appendix Table 4. Information Pertaining to Zone or Subzone Application . 22
Appendix Table 5. Data Supporting Figures 3,4, and 5 . . . . . . . . . . . . . . . . . 23
Appendix Table 6. List of Zones and Subzones by State . . . . . . . . . . . . . . . . 24

U.S. Foreign-Trade Zones: Current Issues
Foreign-trade zones are the U.S. version of free trade zones scattered around
the world. Free trade zones are geographic areas which primarily facilitate economic
development, and co-production — the joint production of a single good through the
efforts of workers in two or more countries. 1 In the United States, this means that
zones are places where some foreign components are typically mixed with U.S.
components in the manufacturing process.
Current policy issues reflect the impact of U.S. zones relative to other influences
on the U.S. economy. Many current legislative proposals tend to focus on finetuning the workings of the zone system or reflect the difference that zone status can
make in promoting economic development for a community and improving
competitiveness of a company in a specific industry.
First, however, this report examines what the U.S. zone system is, how it relates
to zones abroad, and how the U.S. foreign-trade zone program has changed from its
original intent. Tables detail trade zone legislation in the 105th and 106th Congresses,
provide information on application methods and requirements for zone status, and list
zones and subzones, by state.2

U.S. Zones in a World Context
Zones all over the world have an important characteristic in common: They are
geographic areas which are physically inside the boundaries of a country, but which
are treated as if they were located outside the country for customs purposes — that
is, zones are declared to be outside the customs territory of a country.
This separation from the country for customs purposes links world zones
together into a type of international “no-man’s-land,” which has two important traits.
First, no tariffs (taxes on imported goods), and in many cases, (including the United
States) no other taxes (sales, excise, or other) are payable on goods so long as they
remain in the zone system. Only when they leave the system and enter a country are
1

The difference between free trade zones and free trade areas is this: Free trade areas
involve agreement to reduce or eliminate certain trade barriers to all members of the group,
while each country is free to negotiate its own barriers with countries outside the group. Free
trade zones, on the other hand, do not affect a country’s trade barriers. Rather, they set up
secure locations (often fenced) which are inside the boundaries of the country but which are
considered to be outside the country for tariff purposes. Hence, the trade barriers do not apply
as long as the good is within the zone. When the good exits the zone, only if it then enters the
country in which the zone is located, do normal trade barriers apply.
2

While this report mentions a number of specific bills, it is not intended as a bill- tracking
device. It will be updated periodically as needed.

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tariffs payable on the imported value of the product and are sales taxes payable on
imported goods sold. If the goods are re-exported, no duties are payable.
Second, customs procedures are streamlined for all goods entering and leaving
the zone system. As a result, if buttons from Indonesia and fabric from India are sent
to a trade zone in the Philippines for assembly into a shirt, which is then exported to
the United States, no tariffs are payable in the Philippines, and all customs procedures
are streamlined until the completed shirt enters the United States for consumption.
At that time, tariffs are payable on the import value, and the shirt goes through normal
customs procedures.
The 235 U.S. zones are part of the world system of 850 zones.3 Two thirds of
these zones are in developing countries, which produce primarily for export. In these
countries, zones are often used as an economic development tool. Production takes
place in export processing zones which are typically islands of modernization, located
at ports, in countries which lack extensive infrastructure. Supplies which are
unloaded from container ships travel a short distance to be manufactured into
components or completed goods, which are then reloaded on ships for export.
Multinational corporations in developed countries may view these zones as low-cost
offshore production sites.

Characteristics of U.S. Zones
U.S. zones, in contrast with the export emphasis of zones in developing
countries, are primarily for warehousing or processing of imports prior to going
through customs at the port of entry.
U.S. zones differ from other zones around the world in other ways as well. U.S.
imports which are not complete, not yet needed, or not allowed to enter the United
States (for quota reasons, for example) after being unloaded at ports of entry, prior
to facing full customs procedures, may be taken to a nearby foreign-trade general
purpose zone for warehousing or further processing, or to a subzone — a unique
U.S. invention. The 235 zones include seaports, airports, and fenced industrial parks
with warehousing and processing facilities, which are run by public corporations as
if they were utilities — with published rates. Subzones, of which there are about 427,
are manufacturing operations which are administratively linked to a zone, but
physically separated from it. They are typically pre-existing operations which have
3

Zones around the world are called by at least 19 different names, depending on the country
in which they are located or the author or organization referring to them. Among these are the
following: Generically they are often called free trade zones. Those in the United States are
called foreign- trade zones. Those in developing countries producing specifically for export
are typically called export processing zones. They are also called maquiladoras in Mexico,
special economic zones in China, industrial free zones or export free zones in Ireland, free
zones in the United Arab Emirates, and duty free export processing zones in the Republic of
Korea. In addition they are called tax free zones or tax free trade zones by Walter H. and
Dorothy B. Diamond, authors of Tax-Free Trade Zones of the World. They have been called
free export processing zones by the Organization for Economic Cooperation and
Development. Source: International Labor Organisation. Economic and Social Effects of
Multinational Enterprises in Export Processing Zones. Geneva, 1988, p.5.

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applied for and been granted subzone status. However, businesses may also apply for
zone status before beginning construction on a new manufacturing operation.4
U.S. zones and subzones, like other zones around the world, are viewed, in part,
as an economic development tool. They allow businesses to save money on imports
through duty (tariff) deferral, duty exemption, elimination of the need for duty
drawback, and tax avoidance. They also allow U.S. businesses to save small amounts
through quota storage, zone-to-zone transfer, and customs and inventory efficiencies.
(See table 1 for details.) Most importantly, however, subzones in particular, allow
businesses to save money, in part because they are places where inverted tariff
structures can be changed to uniform rate structures (explained below). The ForeignTrade Zones Board estimates that slightly less than 50% of all foreign merchandise
entering through trade zones is being used in the inverted tariff situation.

What is an Inverted Tariff Structure?
An inverted tariff structure means that the tariff rate on a product used as a
component of a finished product is higher than the tariff rate on the finished good
containing the component. When imported components are combined with domestic
supplies in subzones, importers can effectively reduce the tariff rate on components
to the same level as those levied on a completed good.5
Thus, if a zone manufacturer applies for and is granted subzone status, he can
use his zone status to eliminate the adverse cost effect of the inverted tariff in the
industry in which he produces. This is because customs provisions allow zone users
to choose (when the component enters the zone) between paying, (when the
component leaves the zone system as part of a completed good) the tariff on the
component itself or the tariff on the component as if it were incorporated into the
completed good.6 Industries where there may be inverted tariffs include oil refining,
auto manufacturing, electronics, chemicals, food products, pharmaceuticals, apparel

4

Another difference is that many foreign zones allow companies to operate under special or
relaxed rules with respect to taxes and customs oversight. Certain foreign zones require
neither customs documentation or supervision of merchandise while materials are admitted,
stored, or processed in the zone. Some allow significant tax exemptions, including income and
property taxes. U.S. foreign-trade zones, on the other hand, are fully subject to all federal,
state and local laws and taxes, except for federal excise taxes and local inventory taxes. They
are also subject to full customs supervision throughout while materials are admitted,
processed, and shipped, and to customs penalties for failure to adhere to requirements, and to
customs penalties for failure to adhere to requirements. In addition, prohibited goods
(including illegal products) are not allowed into U.S. zones.
5

World Wide Shipping. Economic Impact Analysis, by Dennis Puccinelli, August, 1985, p.
71.
6

The procedure the zone manufacturer follows to change the tariff rate is as follows: When
the duty rate on the imported component is lower than that on the end product into which the
component is to be incorporated, the zone manufacturer must file a formal application for the
component to receive “privileged foreign status.” It such status is approved, the component,
when it leaves the zone, is dutied at its own rate -- typically that applicable to the product of
which it will make an integral part.

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and textiles, steel, and machinery. Not all zone applicants in these industries have
been granted zone status. The granting of zone status by the Foreign- Trade Zones
Board means that zone status has been deemed in the “public interest.” The
determination is based, in part, on the cause of the inverted tariff structure.
Inverted tariffs have arisen in the very extensive Harmonized Tariff Schedule in
two ways: inadvertently, and by design. When an industry has an inverted tariff by
design, it is generally to protect the component industry from import competition. In
such cases, application for zone status may be denied or limitation may be placed on
zone status. Inverted tariff structures are the major reason for zone application in the
United States, and the greatest source of benefit to users (with duty deferral second).
In recent years, tariff levels generally have been negotiated to very low levels, and
typically the differences between tariffs on components and tariffs on finished
products have become smaller and smaller.

Table 1. Possible Cost Savings Available to
U.S. Foreign-Trade Zone Users
Benefit

How Costs Can Be Saved

Duty Reduction
(on Inverted Tariff
Situations)

Zone users may choose the lower duty rate when a product is entered
into customs territory (for importation) in inverted tariff situations
(when the rate of the foreign inputs is higher than the rate applied to
the finished product produced in the zone. Zone status, however, is
granted by the FTZ Board when it determines that such status will
result in a public benefit (typically a net positive effect for U.S.
businesses and workers).

Duty Deferral

Cash flow savings can result because customs duties are paid only
when and if the goods are transferred from the zone to a U.S. customs
territory for import.

Duty Exemption

No duty is payable on goods which are exported from a zone, or
which are consumed, scrapped, or destroyed in a zone.

Drawback
Elimination

Zones eliminate the need for duty drawback. That is, the refunding of
duties previously paid on imported and then re-exported merchandise.

Tax Savings

Goods stored in zones and goods exported are not subject to state and
local ad valorem taxes, such as personal property and sales taxes.

Quota Storage

Cash flow savings and savings from buying in bulk can be made
because U.S. quota restrictions do not apply to merchandise admitted
to a zone until is entered into customs territory. When the quota
opens, the goods may be immediately entered into U.S. customs
territory for importation.

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Benefit

How Costs Can Be Saved

Zone to Zone
Transfer

Zones can transfer merchandise “in-bond” from one zone to another.
Customs duties may be deferred until the product’s eventual entry into
U.S. customs territory.

Customs and
Inventory
Efficiencies

Cost savings (especially cash-flow savings) can occur from zone
efficiencies affecting inventory control. These efficiencies include
customs procedures such as direct delivery and weekly entries.

Source of table data: U.S. Foreign-Trade Zones Board.

How to Achieve Zone Status
The primary constituent interest relating to zones is how to achieve zone status,
as quickly as possible. Appendix table 4, p 20, includes information on how to apply
for zone or subzone status and requirements for applications, together with telephone
and website contacts.7 While new zones are approved when the Board finds that
existing or authorized zones do not adequately serve the “convenience of
commerce,”8 subzones can be approved only when a “public benefit” —(i.e.,
increased employment without detrimental effects on other competitors) can be
clearly demonstrated.9
Zone or subzone status is achieved by applying to the U.S. Foreign-Trade Zones
Board in the Import Administration of the U.S. Department of Commerce in
Washington, D.C. (202) 482-2862. The Board is a committee of two, made up of
the Secretaries of Commerce and the Treasury, whose agencies each play a role in the
approval and oversight of foreign-trade zones.10
The U.S. Foreign-Trade Zones Board is supported by a professional staff of 11,
under the leadership of an executive director. It is responsible for reviewing
applications for zone approval and making recommendations to the Board.
Regulations covering zone application may be found at 15 CFR Part 400. The general
purpose zone applications process takes about 18 months, and the subzone
application process takes about 12 months. Zones are operated by public or public-

7

Most successful zone applicants use general purpose zones for storage, manipulation,
and manufacturing, and special purpose subzones for specific larger scale manufacturing.
However, some creative uses of zones are also emerging. The International Wildlife
Recovery Center has set up an operation in the Medford-Southern Oregon FTZ. The Center
specializes in the decontamination and rehabilitation of wildlife affected by oil and other
hazardous material spills around the world. By locating the center in a foreign-trade zone, in
a pollution event involving 250 birds, for example, the IWRC can save $500,000 in customs
duties associated with food imports for the animals.
8

Foreign-Trade Zones Act, P.L. 73-397, sec. 2(b).

9

Da Ponte, John J., Jr. United States Foreign-Trade Zones: Adapting to Time and Space.
The Maritime Lawyer, Fall, 1980, p. 211.
10

Authority is typically delegated to the Assistant Secretary of Commerce for Import
Administration, and the Deputy Assistant Secretary of the Treasury for Enforcement.

CRS-6
type corporations, which may contract out operations. Zones are operated like
utilities, with published rates.
Day-to-day supervision of goods into and out of zones is the responsibility of the
U.S. Customs Service in the Treasury Department. Customs Service regulations
relating to zones are included at 19 CFR Part 146. Overhead costs for zones include
reimbursement to Customs for services rendered.

How Did the U.S. Foreign-Trade Zones Program Begin?
The Foreign-Trade Zones Board was created by the U.S. Foreign-Trade Zones
Act in 1934 [P.L. 73-397, 19 U.S.C. 81(a)-81(u)]11. It was given the power to
approve applications by public corporations for zone status. The act itself was fairly
short — less than six pages in length. It entitled each U.S. port of entry to at least
one zone, and prescribed physical conditions and standards for each zone,
requirements for operation, recordkeeping, and goods being moved into and out of
zones, activities permissible in zones, and the applicability of all U.S. laws to zones
When the U.S. foreign-trade zones program began in 1934, it was a program
designed to help accelerate U.S. trade in the wake of the restrictive impact of the
Smoot-Hawley Tariff bill of 1930, which raised U.S. tariffs on imported goods as high
as 53%.12 Some have argued that zones were designed originally to be way stations
where goods coming in from one foreign port could be transshipped (reloaded for
export to another foreign port) or re-exported (processed for subsequent export).13
The foreign-trade zones legislation was controversial, however, because there
was some fear that it would promote imports of cheaper components used in the
manufacturing process, and thereby put domestic components manufacturers at risk.
To make sure this would not happen, the Act prohibited manufacturing in zones.

11

Regulations issued by the U.S. Foreign-Trade Zones Board for establishing and maintaining
a foreign-trade zone can be found at 15 CFR 400.
12

Yarbrough, Beth V., and Robert M. The World Economy: Trade and Finance. Harcourt
Brace, 1991, p. 368.
13

U.S. General Accounting Office. Foreign-Trade Zone Growth Primarily Benefits Users
who Import For Domestic Commerce. GAO/GGD 84-52, March 2, 1984, p. 3, 5.

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Changes to the FTZ Act14
After the Foreign-Trade Zone Act was passed, it proved restrictive enough to
be very little used. It did not encourage U.S. exports, as some had expected. Even
sixteen years after the Act was passed, in 1950, there were still fewer than ten
zones.15 Intense lobbying by manufacturing trade groups to make the zone concept
more useful led Congress to permit manufacturing in zones. Many reasoned that
zones were too small for much manufacturing to occur there.
The Foreign-Trade Zones Board took the amendment one step further. This one
step led the zone system on a course which eventually made it successful in a way
that was very different from what some originally intended the program to be. Two
years after Congress passed the amendment permitting manufacturing in zones, the
Foreign-Trade Zones Board issued regulations creating the concept of subzones.
Those regulations declared that when a zone was of insufficient size to accommodate
manufacturing, an employer could apply for subzone status, and thereby have access
to full zone benefits without having to relocate.
Two administrative decisions by the U.S. Treasury Department served to make
zone status even more attractive for manufacturing operations. These decisions —
one in 1980 (U.S. Treasury decision 80-87) and another in 1982, modifying the first
decision, clarified that manufacturers need not pay duty either on value added or on
brokerage or transportation fees connected with imported goods.16

1980s: The Zone System Began Expanding Rapidly
Once the second Treasury decision was handed down in 1982, the zone
program began growing very rapidly and changing in nature, for a number of reasons.
Among these were that the world-wide technological support system
(communications, transportation, merchandise tracking, etc.) was at last ready to
handle the huge demands of expanded international trade. Second, increased
international price competition led U.S. businesses to seek new ways of shaving costs.

14

Historical material in this and the following two sections is taken from: U.S. General
Accounting Office. Foreign-Trade Zone Growth Primarily Benefits Users Who Import For
Domestic Commerce. GAO/GGD 84-52. March 2, 1984, and Foreign-Trade Zones
Program Needs Clarified Criteria. GAO/NSIAD 89-85; U.S. International Trade
Commission. The Implications of Foreign-Trade Zones for U.S. Industries and for
Competitive Conditions Between U.S. and Foreign Firms. USITC Publication 1496,
February, 1984, and The Implications of Foreign-Trade Zones for U.S. Industries and for
Competitive Conditions Between U.S. and Foreign Firms. USITC Publication 2059,
February, 1988.
15

In fact, even as recently as 1970, there were still fewer than ten cities with zones. All of
these were ocean or Great Lakes ports. Source: Da Ponte, John J., Jr. United States ForeignTrade Zones: Adapting to Time and Space. The Maritime Lawyer, Fall, 1980, p. 202.
16

GAO Report, 1984, op. cit., p. 12.

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In addition, the value of the
dollar was quite high in the 1980s,
making cheaper imports even more
attractive.17 On top of this, the Tariff
Schedule of the United States (TSUS,
replaced by the Harmonized Tariff
Schedule in 1989) contained a number
of inverted tariffs. Many inverted
tariffs were later reduced or eliminated
by the Uruguay Round of negotiations
under the General Agreement on
Tariffs and Trade (GATT) in 1994.

Figure 1. Growth in Number of and
Employment in Zones, 1978-1997

700

400

600
300

500
Employment in
Zones

400

200

1997
1996
1995
1994
1993
1992
1991
1990
1989
1988
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978

300
Soon businesses figured out that,
200
if they could achieve zone status, they
100
Number of Zones
could import components in industries
100
and Subzones
with inverted tariff structures,
0
0
assemble them together with domestic
inputs in zones, and import from U.S.
zones products that were less
Source of data: U.S. Foreign Trade Zones Board
expensive to produce by the amount
saved in customs costs on each item
times the number of items. Word of how to take advantage of the inverted tariff
structure and other cost-saving means afforded by zones (reported in table 1) spread
through trade organizations. Zone use and zone employment accelerated
dramatically. (see figure 1.)

Congressional Oversight of Zone Growth
The House Ways and Means Committee, concerned about the potential impact
that zone status was having on U.S. industries (especially domestic components
industries), employment, communities, tariff and tax revenues, competitiveness
abroad, and the U.S. economy in general, asked both the General Accounting Office
(GAO) and the International Trade Commission (ITC) to examine the economic
impact of U.S. foreign-trade zones, in 1983 and again in 1987. Primary findings of
these agencies were that the zone program, while growing rapidly, was having only
a small (but difficult to measure) effect on U.S. revenue collection, employment, and
the economy in general, and a somewhat larger effect on the U.S. components
industry, particularly in the auto sector. Not only did the auto sector have an inverted
tariff, but application for zone status there was reportedly met with relatively little
objection from components manufacturers.18
17

U.S. Congress. House. Committee on Government Operations. Foreign-Trade Zones
(FTZ) Program Needs Restructuring. House Report 101-363. November 16, 1989, p. 11.
18

Quantitative findings included the following:
Effect of Zones on Tariff Revenues: International Trade Commission (ITC) reports
(referred to in footnote 13) found that the net effect of zone operations on customs revenue
was small — 0.04% of total customs duties collected in 1982 and 0.3% of the total customs
(continued...)

CRS-9
One of the most important ITC findings, however, was that the U.S. foreigntrade zones program was doing the opposite of what it was originally intended to do:
The International Trade Commission found that “While a stated intention of the 1934
Act was to increase the competitiveness of U.S. products in foreign markets, zone
status (particularly subzone status) is being used to maintain or improve the
competitive posture of firms in domestic markets (emphasis added).”19 The U.S.
Foreign-Trade Zones Board points out, however, that this statement is not entirely
correct. In fact, the Act itself stated as its purpose “to expedite and encourage
foreign commerce,” favoring neither exports nor imports over the other.20
In 1989, subsequent to the GAO and ITC studies, subcommittees of the House
Ways and Means Committee and the House Government Operations Committee held
hearings on foreign-trade zones.21 In addition, the House Government Operations
Committee issued an independent report on the Foreign-Trade Zones Program. Its
findings were compatible with those reported by GAO and ITC, but went a step
further. It found that the Foreign-Trade Zones Act and program were in need of
extensive revision for failing to carry out what it referred to as “the original intent of
the Act.” The committee report, like the GAO and ITC reports, criticized the
program for promoting instead of exports, domestic competitiveness and imports for
domestic consumption.
The House Government Operations Committee report also criticized the
Foreign-Trade Zones Board, among other things, for poorly conceived and
inefficiently administered processes, for overly general regulations, which failed to list
and use a single set of criteria for granting zone or subzone status, for maintaining
regulations no longer consistent with Board practice, for relying on improperly
conducted economic analyses, for failing to set time limits for stages in the application
process, for failing to certify that operations continue to function in the public interest,
18

(...continued)
duties collected in 1986. (ITC Report 1984, p. xi) and (ITC Report 1988, p. xix-xx).
Per-auto savings by manufacturing in zones: In addition, in 1986, autos accounted
for 87% of all shipments from subzones, seven zones accounting for 76% of total zone
employment. (ITC Report 1988, p. xiv) and (ITC Report 1988, p. 5-2). For auto plants, the
average duty savings per car in 1986-87 was small — about $8.67, down from $9.91 in 1983
and up from $5.54 in 1985 (ITC Report 1988, p. xix).
Employment effect from zones, in the auto industry: Overall, the ITC found a 3.5%
decline in employment in the auto parts sector for new vehicles, and a 1.6% increase in
employment in the auto assembly industry, between 1983 and 1987. (ITC Report 1988, p. 87).
19

U.S. International Trade Commission. The Implications of Foreign-Trade Zones for U.S.
Industries and for Competitive Conditions Between U.S. and Foreign Firms. USITC
Publication 1496, February, 1984, p. viii.
20

Notes received from Dennis Puccinelli, Executive Director of the U.S. Foreign-Trade
Zones Board, July 16, 1999.
21

U.S. House. Committee on Ways and Means. Subcommittee on Trade. October 24, 1989.
Operation of the Foreign-Trade Zones Program of the United States and its Implications
for the U.S. Economy and U.S. International Trade. Serial 101-56. 442 p. and U.S. House.
Committee on Government Operations. Subcommittee on Commerce, Consumer, and
Monetary Affairs. March 7, 1989. Foreign-Trade Zones. 343 p.

CRS-10
and for failing to operate in a manner consistent with trade policy.22 The Committee
made a number of recommendations to address these perceived weaknesses.
Ultimately, in October 1991, in consultation with congressional committees, the
Board issued new regulations aimed at codifying its existing practice and meeting
congressional criticisms.
In addition to congressional requests to the GAO and the ITC, hearings, and the
report mentioned above, continuing periodic congressional interest in foreign-trade
zones has been part of a broader focus on trade issues. Zone issues have been
addressed by minor amendments to the Foreign-Trade Zones Act and been included
in a number of more inclusive hearings and trade laws over the years. Some of the
amendments have increased the benefits of zone imports and exports.

The Zone System Today
Today, as during the 1980s, zones are predominantly instruments for changing
inverted tariff structures into uniform rate structures. This is the case even though
subzone users may save money in a variety of other ways (listed in table 1) and even
though tariffs overall have declined considerably in the past 15 years, from an average
rate of 5.5% in 1984 to an average rate of 2.0% in 1998.23 Today, instead of being
places where relatively large tariff savings — (i.e., $5-10 per car, for example) can be
made on a few major components, zones are now more typically places where small
savings (i.e., $1-3 per car, using the same industry example, according to the ForeignTrade-Zones Board) can be made on a larger volume of components.24 While the
auto industry is still a prime beneficiary of zone status, the petroleum industry is the
primary user now, accounting for 64% of the value of all goods entering zones (see
figure 6), with motor vehicles accounting for another 23%. Some of the auto
production operations have moved offshore, and large numbers of petroleum
operations are still applying for zone status.
The importance of trade zones today is evidenced by the following statistics:
Since 1970, the total number of trade zones and subzones combined has grown from
10 to 662, and employment in them has increased from 7,000 to 367,000, as was
shown in figure 1. Nevertheless, zones (including subzones) represent only a small
part of the U.S. economy. The total zone employment accounts for only 0.2% of
total U.S. employment. In addition, all zone inputs (both domestic and foreign — a
total of $178 billion in 1997) represent only a small part — 2% of U.S. gross
domestic product ($8,111 billion in 1997). While the world-wide zone system plays
a large role in international trade, it should be noted that very few imported zone
inputs in these industries enter the U.S. zone system from other zones around the
22

Foreign-Trade Zones (FTZ) Program Needs Restructuring, p. 19-24.

23

Data for 1984 from U.S. Department of Commerce, Bureau of the Census. Highlights of
U.S. Export and Import Trade, FT990/December, 1984, Table 9, p. C-31. Data for 1998
from http://dataweb.usitc.gov.
24

Savings on a particular item may result from the rationalization of inverted tariffs together
with other savings of the types detailed in figure 1.

CRS-11
world. In addition, only a small part of all U.S. imports (6%) enter the United States
through zones in other countries.25
The map in figure 2 shows the states in which zone and subzone use is
concentrated (darker shading). Zone and subzone use is concentrated primarily in
traditionally heavy industrialized states where there is considerable auto
manufacturing and in coastal states where there is considerable oil importing.
Figure 2. Concentrations of U.S. Foreign-Trade
Zones and Subzones Among States

Source of data: U.S. Foreign-Trade Zones Board.
See appendix table 6 for listing of zones by state.

25

1-10 zones and subzones
10-20 zones and subzones
20-90 zones and subzones

Zone data are taken from U.S. Department of commerce. Foreign-Trade Zones Board. The
59 th Annual Report of the Foreign-Trade Zones Board. Employment data are taken from
U.S. Department of Labor. Employment and Earnings (any issue), table B-1. U.S. GDP data
are taken from Economic Report of the President, 1999, p. 342.

CRS-12

Zones Today are Functionally Import Rather Than Export Zones
Figure 3. Extent to Which Imports
Entering Zones are Subsequently
Re-Exported, 1978-1997

Exports/Imports
%
100

U.S. Zones as Export Zones
80

60
50
40
U.S. Zones as Import Zones

20

0
1997

1996

1995

1994

1993

1992

1991

1990

1989

1988

1987

1986

1985

1984

1983

1982

1981

1980

1979

1978

Zones today are primarily
import zones, rather than
export zones as some observers
believe Congress originally
anticipated. They are import
zones in terms of both zone
inputs and zone outputs, even
though both the Act itself and
the Foreign-Trade Zones Board
are currently neutral on this
issue. In addition, the fact that
most
U.S.
zones
are
functionally import zones
reflects both the economic
maturity (in comparison to
developing countries) and the
relative strength of the U.S.
economy.

Source of data: U.S. Foreign Trade Zones Board, Annual Reports, various years.

In terms of zone inputs, today’s zones have lately become “import” zones in
that, in recent years, more goods entering the zones have been subsequently imported
into the United States than exported. In figure 3, export years (1981-95) are those
in which the thick black line remains above the 50% line. Import years (1978-91 and
1996-97) are represented where the line dips below the 50% line. (See appendix table
6 for data supporting figures 3, 4, and 5.)
In terms of zone outputs,
today’s zones are import zones
rather than export zones in that
the majority of zone output is
imported into the United States,
and very little is exported.
Figure 2 shows that since 1984,
the proportion of total zone
output that is exported has
averaged about 10-15%.

Exports/total zone inputs

%
100
80
Zone output that is consumed
domestically

60
40
20

Zone output that is exported

0

1997

1996

1995

1994

1993

1992

1991

Source of data: U.S. Foreign Trade Zones Board,
Annual Reports, various years.

1990

1989

1988

1987

1986

1985

1984

1983

1982

1981

1980

1979

1978

Figures 3 and 4 both show
that 1982 is the year when zones
reached their pinnacle as export
zones.

Figure 4. Extent to Which Total Zone Output
is Consumed Domestically
or Exported 1978-1997

CRS-13

Zones Today are Primarily “Domestic-Trade” Rather Than
“Foreign-Trade” Zones

1997
1996
1995
1994
1993
1992
1991
1990
1989
1988
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978

Zones can also be
Figure 5. Source of Zone Inputs (Domestic
classified today as being
or Foreign) 1978-1997
functionally “domestic-trade”
zones rather than “foreignDomestic Inputs/
trade” zones. This is because
Total Inputs
most of the inputs into the
%
100
zones are of domestic origin,
Inputs are Primarily
even though the gains to be
Domestic
80
made from zone status stem
from imports. (See table 1 for a
60
listing of the type of gains to be
50
made from zone status.) Since
40
1983, zone inputs sourced
domestically have accounted for
20 Inputs are
Primarily
more than half, and since 1985
Foreign
they have accounted for about
0
75-80% of all zone inputs. (See
figure 5). The fact that the
Source of data: U.S. Foreign Trade Zones Board,
Annual Reports, various years.
percentage of domestically
sourced zone inputs has
declined somewhat in the last few years reflects a greater presence in zones of oil
refining, which uses primarily imported crude, compared to auto assembly, which uses
mostly domestic components.
Calling zones “import” zones rather than “export” zones, and “domestic” zones
rather than “foreign” zones is another way of reiterating what the ITC found in the
1980s: Instead of increasing the competitiveness of U.S. products in foreign markets,
zone status is still being used
(with the support of the Act) to
maintain or improve the Figure 6. Industry Concentrations of Imports
in Zones, 1984 and 1997
competitive posture of firms in
domestic markets.
Percent of all zone input
accounted for by named industry
70
60

Industry Concentrations
in Zones Have Changed

50
40
30
20

1984
1997

23% 25%
10%

5%

5%
1% 2% 1% 0.4% 5%

10

Source of data: 46th and 59th Annual Reports of the
Foreign Trade Zones Board.

Other

Food Products

Chemicals

Electronics

Motor Vehicles

0

Petroleum Refining
& Storage

Industry concentrations in
zones have changed since the
mid-1980s, as mentioned
previously. Figure 6 shows
that in 1984, motor vehicle
assembly plants accounted for
60% of all imports into zones,
and electronics companies were

64% 60%

CRS-14
the second greatest users of zones. By 1997, many electronics and auto assembly
plants had relocated abroad, and petroleum refining had become the dominant zone
user. Today, the two industries account for 87 % of all zone inputs.

The Future of Zones
Overall, most tariffs have continued to be reduced to very low levels in the
United States, through numerous trade agreements or establishment of free-trade
areas. This would arguably point to an accompanying reduction in the use of trade
zones. Inverted tariffs will lose their significance when all duties are near the same
level. In addition, the nominal cost savings of duty deferral in a country with low
tariff rates, like the United States, would make zone status an unnecessary
administrative burden in addition to its reduced effect as a protectionist device.26
Similarly, the gradual phasing out of quotas will also diminish demand for zone use.
However, at the same time, computers are facilitating zone use by making it
easier for corporations to search through tariffs on all imported parts that potentially
go into making a certain item, in order to identify those that represent an inverted
tariff structure. Computers also make it easier to keep track of quota fulfillment and
to calculate final tariffs owed on a large and diverse array of small imported
components. Thus, smaller savings from zone use, including logistical and
administrative savings, may be relatively more important than they once were.
Applications for zone or subzone status are still being approved. In 1997, the
U.S. Foreign-Trade Zones Board approved 8 new general-purpose zones and 37 new
subzones — consistent with the rate over the past several years — increasing the total
number of zones by 3.5% and subzones by 9.5%
Thus, even though businesses may be reaping smaller savings per imported item
used in zones, they may be able, in some cases to expand the number of items on
which they save money. In addition, international competition has become sufficiently
great in recent years that even very small savings from zone status, through duty
reduction, deferred duty payment, duty exemption, tax savings, quota storage, or
other means outlined in table 1 can make important contributions to U.S.
competitiveness.

Policy Issues Relating to Zones
Many of the zone-related policy issues that were prominent ten years ago are
less important today, because the circumstances that surround them have changed:27

26

Kanellis, William G. Reining in the Foreign-Trade Zones Board: Making ForeignTrade Zone Decisions Reflect the Legislative Intent of the Foreign-Trade Zones Act of 1934.
Northwestern Journal of International Law and Business, Spring, 1995, p. 635.
27

The major issues of the late 1980s were documented in the GAO and ITC reports
(continued...)

CRS-15
In the 10 years since the GAO, ITC, and congressional studies were conducted,
foreign-trade zones have become much less an issue of congressional focus than they
were. This has occurred, in part because congressional interest has shifted from the
employment and competitive effects of zone status to increased importation of
manufactured goods and the effect this is having on U.S. jobs and the U.S. economy
in the long run. Economists argue that with increased trade, everybody wins;
however, dislocation of workers in various sectors has become an important
congressional concern.

Is the Congressional Intent of the Foreign-Trade Zones Program
Being Met?
The answer to a question on whether the congressional intent on zones is being
met depends on whether one judges congressional intent at the time of passage of the
U.S. Foreign-Trade Zones Act, or as it has evolved over the past 65 years.
Some of the pre-passage debate suggested hope that the zones would boost
exports rather than imports. In addition, while the preamble of the act emphasized the
promotion of trade without reference to either exports or imports, section 3 of the
Act did strictly prohibit manufacturing in zones (sec. 3). This language is consistent
with arguments that manufacturing was prohibited in order to discourage the
importation of cheaper components which would compete with domestically
produced components.
Amendments to the Act over the years, however, have reflected a gradual shift
in congressional intent toward greater acceptance of zones for handling imports. The
1950 amendment permitted manufacturing in zones, thus reversing the original
exclusion. In addition, certain other amendments, including a 1990s amendment
providing for evaluation of products upon importation from a zone, make specific
reference to imports (sec. 81c, of title 19 of the U.S. Code)28.
Therefore, one could conclude that the congressional intent as it has evolved
over the years is being met. In addition, the shifting of congressional focus on the
zone issue from major oversight and evaluation to minor tinkering reflects an apparent
acceptance of the U.S. zone system as it stands today.

27

(...continued)
previously mentioned, and also in U.S. Library of Congress. Foreign-Trade Zones and the
U.S. Automobile Industry, by Gwenell L. Bass, and Lenore Sek. CRS Report 88-659E,
October 14, 1988.
28

Any program that specifically promoted exports to the detriment of imports could violate
WTO rules against export subsidies.

CRS-16

Have Foreign-Trade Zones Helped or Hurt U.S. Workers and
Businesses?
The question about whether zones have helped or hurt U.S. workers is seen
differently in the 1990s than in the 1980s. Some employment effects from trade with
Mexico and Canada since the North American Free Trade Agreement (NAFTA) went
into effect and from trade with developing countries generally and under the General
System of Preferences (GSP),29 have shifted the perspective on the effects of trade
zones on U.S. jobs.
By way of comparison, in the 1980s, there was some alarm that increased use
of U.S. foreign-trade zones was leading to the loss of U.S. jobs. The International
Trade Commission estimated that for the four-year period 1983-1987, trade zones
reduced overall employment in the auto industry by a net 1.9%. This represents a
gain in the auto assembly sector and a loss in the auto parts sector.30 Concern over
the effect of zones on employment, however, has been eclipsed in recent years by
concern over the effect of trade agreements [especially the North American Free
Trade Agreement (NAFTA)] on employment. A difference in the order of magnitude
on a particular industry is shown in the following example: In the 1990s, over a five
and one-half year time period after NAFTA went into effect, increased trade with
Mexico and Canada led to a 5.3% job loss in the apparel sector.31
Thus, small benefits from avoiding the higher tariff rates in industries with
inverted tariffs (differentials which are continually shrinking) may seem less important
today than they did a decade ago. In addition, in the 1980s, trade zones were viewed
as a way of encouraging U.S. manufacturing plants to remain in the United States
rather than relocate abroad. Today, the potential cost savings from using zone status
to avoid the penalties of an inverted tariff (which may be only a percent or two) seem
small compared to the potential cost savings which some businesses can obtain by
relocating a labor-intensive plant to Mexico or some other country with a preferential
system (i.e., GSP, CBERA, or Andean), and thus saving large amounts from wage
differentials.32

29

The General System of Preferences provides duty-free treatment under specific conditions
for 142 developing countries.
30

A FTZ Board letter to the file documenting a March 3, 1988 meeting with the ITC
economist who developed the economic model which was the basis for the ITC findings
indicates that the model was meant to provide estimates rather than definitive numbers on jobs
gained or lost as a result of zone procedures.
31

For 1983-87 data for the motor vehicle transportation sector (SIC 37), see ITC Report,
1988, p. 8-7, and U.S. Department of Labor, Bureau of Labor Statistics. Employment,
Hours, and Earnings United States 1981-93, bulletin 2429. For data on the apparel sector
(SIC 23), see NAFTA: Estimates of Job Effects and Industry Trade Trends After 4 ½ Years,
by Mary Jane Bolle. CRS Report 98-783E, p. 8, and Employment, Hours, and Earnings
United States 1990-95, Bulletin 2465.
32

The Caribbean Basin Economic Recovery Act (CBERA), applying to 27 Caribbean
nations, and the Andean Initiative (applicable to imports from Bolivia, Ecuador, Colombia,
and Peru) are similar to the GSP in that they offer duty-free treatment under specific
(continued...)

CRS-17

Table 2. Potential Winners and Losers From Zone Use33

Manufacturers

Potential Winners

Potential Losers

Final assemblers could win to the extent
that righting an inverted tariff lets them get
components at a lower cost.

Components manufacturers could lose to
the extent that the product becomes less
competitive with imported components.

Components manufacturers could win to
the extent that they can automate, become
more competitive with imports, and
thereby save on production costs.
Workers in assembly operations could win
to the extent that FTZ status results in
greater profits which may be passed along
to workers.

Workers

Either automation, or plant closings, in
components industries from losing sales to
importers operating in zones, could put
workers out of jobs.

Workers in “losing” industries could win to
the extent that job loss encourages them to
upgrade skills, which could them lead to
higher paying jobs.
Community

Any zone effects could have ripple effects
on the community. Communities with new
zones may benefit because zones can
attract new business into the area.

Communities with component
manufacturing operations that close may
suffer.

Consumers

To the extent that FTZs help manufacturers
reduce prices and those prices are passed
along to consumers, consumers could
benefit.

Consumers may suffer from reduced
choices or reduction in quality to the extent
that foreign-trade zones encourage the
substitution of cheaper imported
components or goods for domestically
produced ones.

Tariff Revenues

Total U.S. tariff revenues increase to the
extent that increased zone use results in an
increased demand for the imported
components.

Tariff revenues decline by the difference
between the tariff on the component and
the tariff on the finished product for each
item imported into a zone, times the
number of items.a

Tax Revenues

Total U.S. tax revenues increase to the
extent that increased zone use results in an
increased demand for the product and in
greater earnings for each worker producing
goods in zones. Increased tax revenues
would come from increases in U.S. income
tax collections brought about by increased
profits and wages, federal excise taxes, and
state and local taxes of the types affected by
increased business.

32

(...continued)
conditions.
33

These arguments were largely drawn from GAO and ITC reports.

CRS-18
a

An example showing the potential magnitude of such tariff revenue loss is an ITC finding that zone use reduced
overall tariff revenues by 3% for 1986. Overall customs duties of $1,216 million represented an overall duty savings
of nearly $39 million on the U.S. economy from foreign-trade zone use in 1986. This represents a total loss of about
3% of tariff revenues for 1986. Source of duty savings: 1988 ITC report, op. cit. Source of overall duties: Highlights
of U.S. Export and Import Trade, op. Cit., 1986.

In addition, the question of whether zones have helped or hurt U.S. businesses
invites a mixed response. Table 2 shows typical winners and losers from zone use.
Certainly businesses that have applied for and achieved zone status have benefitted. On
the other hand, once one business in an industry achieves zone status, others are forced
to follow suit to remain competitive. As a result, once auto assembly plants
started getting zone status, virtually all others in the industry followed suit.34 Today,
this is occurring in the oil refining industry.
On the other hand,zone regulations require that U.S. zone activity have a net
positive effect for U.S. businesses and workers. In addition, the 1991 regulations
applicable to the Foreign-Trade Zones Board specifically require that the Board
disallow any actions that would circumvent U.S. trade policy or programs developed
by the administration and Congress. In keeping with this policy, the Board has
disapproved applications that proposed to use the Foreign-Trade Zones program to
circumvent sugar, milk, textile and apparel quota programs in an attempt to prevent
situations where there are “losers” (businesses or workers).

Does the Zone System Set U.S. Trade Policy by Circumventing
Congress and U.S. Trade Negotiators?
It can be argued that the U.S. zone system sets trade policy by circumventing
Congress and U.S. trade negotiators. The decision to lower tariffs is thus shifted from
the traditional method involving Congress and U.S. negotiators to an alternative
method involving the U.S. Foreign-Trade Zones Board and its approval of the use of
zones by representatives of various industries. However, as mentioned, the gradual
decline of tariffs from an average rate of 5.5% to 2.0% between 1984 and 1998 has
somewhat diminished the influence of the Foreign-Trade Zones Board on U.S.
effective tariff rates. In addition, the Foreign-Trade Zones Board is adamant that if it
perceives that zone status in an industry (usually the assembly sector) will harm the
components sector, it will deny or limit zone status. Industries where zone status has
been denied or limited for this reason include textiles, steel, pigments, TV tubes, ink,
ethanol, chain saws, lawn mowers and agricultural products (e.g. dairy and sugar, and
orange juice.)35

34
35

Bass and Sek, op. cit., p. 11.

From a telephone conversation with Dennis Puccinelli, Executive Director of the U.S.
Foreign-Trade Zones Board on May 21, 1999.

CRS-19

Legislation Relating to Zones
In the last ten years, legislative issues relating to zones have shifted from the
macro to the micro level. Instead of being focused on how zones affect the U.S.
economy, they are now more focused on whether zone policy should be used to help
specific industries.
Nor does foreign-trade zone legislation in the 105th and 106th Congresses attempt
to reverse the evolutionary changes which have affected U.S. foreign-trade zones. The
current legislative proposals are much more narrowly focused on changing trade policy
for various industries and promoting economic development. Bills relating to the
foreign-trade zone system fall into four categories: technical corrections relating to
zones; bills to help achieve trade objectives through zones (i.e. legislation relating to
steel, peanut butter, or tobacco products); legislation to assist zone expansion or
promote economic development; and legislation to support specific programs (i.e.,
space exploration). (See table 3 on major zone legislation).
P.L. 105-303, enacted in the 105th Congress, included a foreign-trade zone
provision to further encourage the development of the commercial space industry. It
clarifies that payloads launched from trade zones shall be considered exports (not
imports) with regards to customs entry.

Technical Corrections Relating to Zones
In the 106th Congress, Sec. 2405 of P.L. 36, signed by the President on June 25,
1999 (S. Report 106-2) makes technical corrections to various trade laws. It
provides, among other things, that the Secretary of the Treasury shall include
commercial importation data for foreign-trade zones in the new program automating
customs procedures (the National Customs Automation Program) — which is
currently undergoing both construction and funding difficulties.

Legislation to Achieve Trade Objectives For Specific Industries
A number of bills relating to U.S. foreign-trade zones in the 106th Congress,
would accomplish trade objectives by affecting the way certain imports are treated.
H.R. 975, passed by the House on March 17, 1999, (H. Report 106-52) provides for
a reduction in steel imports. It requires a steel notification certificate before steel is
entered into the U.S. customs territory of the United States.
Other legislation in the 105th Congress would have related to the tobacco industry
by providing for an increase in taxes on tobacco products which enter the United
States through a foreign-trade zone (H.R. 1229), and prohibiting the manufacturing
of tobacco products in or forwarding them through foreign-trade zones, or selling them
in or to duty-free shops (H.R. 3738.)
Also in the 105th Congress H.R. 1875 would have allowed the entry of peanut
butter and paste from Mexican peanuts through foreign-trade zones without being
subject to the tariff rate quota.

CRS-20

Legislation to Assist Zone Expansion or Promote Economic
Development
Other bills would aim to promote economic development by directing the U.S.
Foreign-Trade Zones Board to grant approval for new or expanded zones. In the 106th
Congress, H.R. 465 would direct the Board on behalf of the municipal airport of
Chico, California. H.R. 5401 would make this direction for zones on Indian territory.

CRS-21

Table 3. Some Major Zone Legislation of the 106th and 105th Congresses

106th Congress
P.L 106-36: H.R. 435/S. 262 (S.Report 106 -2) made technical changes to various trade laws. It also
included a provision (Sec. 2405) which stated that not later than Jan. 1, 2000, the Secretary of the
Treasury shall provide for the inclusion of commercial importation data for foreign-trade zones under
the National Customs Automation Program. On June 7, 1999, the House agreed to Senate amendment,
roll call #168.
Passed the House March 17, 1999: H.R. 975 (Visclosky). H.Report 106-52 provides for a
reduction in the volume of steel imports. For steel brought into the United States through a foreigntrade zone, requires a steel notification certificate before the merchandise is entered into the customs
territory of the United States.
Other Bills:
H.R. 465 (Herger) directs the Foreign-Trade Zones Board to expand Foreign-Trade Zone No. 143 to
include an area of the municipal airport of Chico, California.
S. 401 (Campbell, Nighthorse), Sec. 205 provides for business development and trade promotion for
Native Americans. Directs the U.S. Foreign-Trade Zones Board to consider on a priority basis and
expedite processing of any application aiming to establish a foreign-trade zone on Indian territory,
including any designated an empowerment zone or enterprise community.

105th Congress
Enacted: H.R. 1702 (Sensenbrenner, P.L. 105-303, Oct. 28, 1998: To encourage the development of a
commercial space industry in the United States, and for other purposes. Sec.102: Clarifies that a
launch vehicle is not, because of launch or reentry, an export or import. However, payloads launched
pursuant to foreign-trade zone procedures shall be considered exports with regard to customs entry.
This means that if any part of the launch vehicle or its payload is imported (for example part of the
fuel), no tariffs are payable.
Other Bills
H.R. 1875 (Crane) would amend the U.S. Harmonized Tariff Schedule to allow entry of peanut butter
and paste from Mexican peanuts in foreign-trade zones without being subject to the tariff rate quota.
H.R. 1319 (Royce), Sec. 204 would abolish the Department of Commerce and transfer the U.S.
Foreign-Trade Zones Board to the Department of the Treasury. The U.S. Trade Representative would
replace the Secretary of Commerce on the Foreign-Trade Zones Board.
H.R. 1229 (Ackerman), Sec. 301 provides for an increase in taxes on tobacco products, cigarette
papers, or cigarette tubes entered into a customs territory from a foreign-trade zone.
H.R. 3738 (Doggett), Sec. 407: prohibits against the sale of tobacco products in or to duty-free shops
or forwarding through or manufacturing in foreign-trade zones.
S. 1415 (McCain): Section 1147 is similar to the provision in H.R. 3738.

CRS-22

Appendix
The appendix includes information on how to apply for zone status, data supporting
figures 3, 4, and 5, and lists, zones and subzones, by state.

Appendix Table 4. Information Pertaining to Zone or Subzone Application

How To Apply for Zone or Subzone Status
C
C

C
C

Apply to the U.S. Foreign-Trade Zones Board, Import Administration, U.S. Department of
Commerce, Washington, D.C. 20230 (202) 482-2862.
Basic requirements for foreign-trade zone applications are found in 15 CFR Part 400, available at
the U.S. Foreign-Trade Zones Board website:
http://www.ita.doc.gov/import_admin/records/ftzpage/ftzhome.html.
Applications are rather involved, and the approval process is somewhat lengthy. General Purpose
Zone applications take about 18 and Subzone applications about 12 months.
After application approval is granted by the Foreign-Trade Zones Board, before operations can
take place, approval to activate the zone must be obtained from the Customs Port Director.

Zone Status:
C
C
C
C
C
C
C
C
C
C

Zone status is typically granted to state or local agencies or public type corporations (i.e., port
authorities or economic development agencies), which may contract out operations.
Zone sites must be in or near U.S. Customs ports of entry (listed at 19 CFR Part 101).
Zones are operated under the day-to-day supervision of the U.S. Customs Service. Overhead costs
include reimbursement to Customs for services. See regulations at 19 CFR Part 146.
Operations are conducted as public utilities, with published rates.
Zone projects should be coordinated at the state level for consistency with economic development
plans.
Applicants must have a suitable plan including provisions for facilities and financing.
Need for the proposed zone must be shown in terms of the local economy and overall economic
development objectives.
Zone manufacturing is reviewed under “public interest” criteria for consistency with trade policy
and net positive economic effects.
Zones should help create, not just divert employment from region to another.
There must be convincing evidence of a need for zone services. Letters of intent from firms
expecting to be the first zone users should be included in the application.

Subzone Status:
C
C
C

Subzones are normally private plant sites that usually cannot be accommodated within an existing
general-purpose zone.
Subzones can be approved only when a “public benefit” resulting in a “positive economic effect” is
demonstrated
Subzone applications include: company background, product description, industry background,
zone benefits to the company and public, impact on the domestic industry and environment.

Source of the above information: websites of the U.S. Foreign-Trade Zones Board (listed above), the
U.S. Customs Service: http://www.customs.ustreas.gov/imp-exp2/comm-imp/ftz/ftstart.htm, and the
National Association of Foreign-Trade Zones: http://www.imex.com/naftz.html.

CRS-23

Appendix Table 5. Data Supporting Figures 3, 4, and 5
(In $billions, and percent)
Data for
Figure 4

Data for
Figure 3

—

—

Data for
Figure 5

Exports
from Zones/
Imports Into
Zones
(%)

Domestic
Inputs/Total
Inputs
(%)

—

Mdse
Received in
Zone
($billions)

Domestic
Inputs
($billions)

Foreign
Inputs
($billions)

Exports
($billions)

Exports as
% of Mdse.
Received in
Zones
(%)

1978

0.81

0.17

0.63

0.24

30

38

21

1979

1.52

0.43

1.09

0.35

23

32

28

1980

2.60

0.89

1.71

0.69

27

40

34

1981

3.02

1.03

1.99

0.93

31

47

34

1982

3.40

1.32

2.08

1.54

45

74

39

1983

6.51

3.61

2.90

1.67

26

58

55

1984

15.00

10.50

4.50

2.65

18

59

70

1985

24.75

19.01

5.74

3.89

16

68

77

1986

40.19

31.07

9.12

4.87

12

53

77

1987

48.95

38.42

10.52

5.40

11

51

78

1988

58.65

44.56

14.10

7.22

12

51

76

1989

76.27

57.51

18.76

10.75

14

57

75

1990

90.06

70.64

19.42

11.59

13

60

78

1991

84.44

66.42

18.02

10.48

12

58

79

1992

98.69

78.39

20.30

11.65

12

57

79

1993

103.97

80.16

23.81

11.65

11

49

77

1994

119.57

93.61

25.96

17.37

15

67

78

1995

143.51

114.37

29.14

16.94

12

58

80

1996

168.62

125.68

42.94

17.09

10

40

75

1997

177.85

121.16

56.69

16.93

10

30

68

Source of data: U.S. Foreign-Trade Zones Board.

CRS-24

Appendix Table 6. List of Zones and Subzones, by State

STATE

ZONE# SUBZONE #

LOCATION

BUSINESS

INDUSTRY

YEAR
APPROVED

ALABAMA
82
83
98
211
222
233

Mobile
Huntsville
Birmingham
Anniston
Montgomery
Dothan
116 Mobile
ADDSCO
shipbuilding
137 Huntsville
Chrysler
auto electronics
159 Mobile
Degussa
methhionine
293 Foley
Peavey
electronics
329 Tuscaloosa Mercedes-Benz motor vehicles
334 Dothan
Sony
magnetic &
336 Madison
MagneTec
lighting ballasts
351 Mobile .
Zeneca
ag. chemicals
368 Tuscaloosa. ZFIndustries
auto axles
382 Mobile Cnty. Coastal
oil refining
392 Tuscaloosa JVC America
videotape prds.

88
88
89
95
96
96
96
96
97
97
97

Valdez
St. Paul
Anchorage
Fairbanks
Kodiak
256 Fairbanks

pipeline insulation

93

Pima
Nogales
Phoenix
Sierra Vista
Pima
Yuma
Mesa
197 Glendale
Conair
small appliance
250 Buckeye
Wal-Mart
distribution
269 Chandler
Intel
semiconductors
323 Phoenix
SGS-Thompson semiconductors
353 Casa
Abbott Mfg.
infant formula
354 Phoenix
PETsMART
warehouse/distrib
375 Phoenix
Sumitomo Sitix semionductor
420 Chandler/Te Microchip
semiconductors
427 Yuma
Meadowcraft
patio furniture

91
93
94
96
96
96
97
98
98

Little Rock
16 Forrest City Sanyo
microwave ovens
350 West Helena Cedar Chemical ag. chemicals
376 El Dorado
Mid States Pipe steel pipe fab.

82
96
97

ALASK
108
159
160
195
232

Flowline

ARIZON
48
60
75
139
174
219
221

ARKANSAS
14

CALIFORNIA
3
18
50

San
San Jose
Long Beach

STATUS: (Active
unless otherwise
indicated)

CRS-25

STATE

ZONE# SUBZONE #
56
143
153
191
202
205
226
230

LOCATION

BUSINESS

INDUSTRY

YEAR
APPROVED

Oakland
W.
San Diego
Palmdale
Los Angeles
Port
Merced
Stockton
1 San
Lilli Ann
aparel
25 Long Beach Toyota
truck beds
30 San Jose
Olympus
med. equip.
54 San Diego
National Steel & shipyard
56 Fremont
NUMMI
auto
147 Benecia
Mazda
auto
178 Perris
National RV
motor home/RV
233 Pasadena
Datatape
tape recording
276 Garden
Alps Mfg.
computer etc.
332 Auburn
C. Ceronix
video monitors
380 Los Angeles MMM
pharmaceuticals
385 Sacramento Hewlett-Packar computer-related
398 Dixon
Gymboree
apparel/toys
400 El Segundo Checron
oil refining98
408 Richmond
Chevron
oil refining
412 Fremont
Cirrus Logic
integrated circuit
419 San Jose
Hewlett-Packar computer etc.

63
83
83
84
84
89
90
92
94
98
97
97
98
98
98
98
98

El Paso
Denver
226 Fountain
234 Boulder
415 Broomfield

data proc. equip
electronic storage
elec. power

92
92
98

pharmaceuticals

90

Wilimington
Wilmington J. Schoeneman apparel
42 Newark
Chrysler
auto
47 Wilmington Ge. Motorsauto -286 Newark
Zeneca
pharmaceuticals
340 Newastle
Star Enterprise oil refinery

84
84
84
94
96

COLORADO
112
123

Apple
Storage
Artesym

CONNECTICUT
71
75
162
208

Windsor
Bridgeport
North Haven
New London
174 West Haven Miles

DELAWARE
99
41

FLORID
25
32
43
64
65
79
135
136
166

Broward
Miami
Orlando
Jacksonville
Panama City
Tampa
Palm Beach
Brevard
Homestead

STATUS: (Active
unless otherwise
indicated)

CRS-26

STATE

ZONE# SUBZONE #
169
180
193
198
209
213
215
217
218

LOCATION

BUSINESS

INDUSTRY

YEAR
APPROVED

Manatee
Miami
Pinellas
Volusia & Flagler Counties
Palm Beach County
Fort Myers
Sebring
Oscala
St. Lucie County
204 Cocoa
Flite
231 Melbourne American
277 Tampa
Reilly Dairy
281 Tampa
Group
355 Ft.
Federal-Mogul
407 Miani
Hewlett-Packar
411 Broward
CITGO
426 BrevardCou Harris Corp

machinery
telecom./compute
dairy prds.
electronics
vehicle parts dist.
computer etc.
petrol. storage
telecommunicatio

91
92
94
94
97
98
98
98

Atlanta
Savannah
Brunswick
24 Atlanta
46 La Grange
70 Hapeville
149 Coweta
296 Dougherty
299 Bulloch
330 Chatham
346 Columbus
347 Columbus

GM
Goetze Gasket
Ford
Yamaha
Merck
Wal-Mart
CITGO
Pratt& Whitney
Precision

auto
auto gaskets
auto
golf carts/water
pharmaceuticals
distribution
oil refining
United
aircraft engine

83
84
85
98
95
95
96
96
96

Honolulu
2 Oahu
57 Honolulu
95 Kahului
72 Honolulu
138 Oahu
364 Oahu

Tesoro Hawaii
Kerr Pacific
Maui pineapple
Dole
Chevron
Gasco

refinery
-food
food
oil refining
oil refining

70
95
86
85
88
97

steel pipe fab.83
tractor
auto
packaging
packaging
packaging
auto

83
85
86
87
87
87
87

STATUS: (Active
unless otherwise
indicated)

GEORGIA
26
104
144

Lapsed

HAWAII
9

IDAHO
192

Meridian

ILLINOI
22
31
114
133
146
176

Chicago
Granite City
Peoria
Milan
Lawrencevill
Rockford
22 Chicago
UNR-Leavitt
60 Peoria
Caterpillar
89 Chicago
Ford
98 Du Page
Power
99 Du Page
Power
100 Kane
Power
104 Belvidere
Chrysler

Lapsed

expired 91
expired 91
expired 91
transferred 93

CRS-27

STATE

ZONE# SUBZONE #

LOCATION

BUSINESS

INDUSTRY

YEAR
APPROVED

112 Flora
N. Am. Lighting auto components
113 Salem
N. Am. Lighting auto components
114 Peoria
Mitsubishi
auto
154 Galesburg Maytag
appliances
155 Herrin
Maytag
appliances
220 Effingham
Fedders
room air
222 Dundee
Milk
animal feed
224 Loves Park Clinton
cathode ray tubes
243 N. Chicago Abbott
pharmaceuticals
275 Des Plaines Sanofi
pharmaceuticals
306 Manhattan Amoco
crude storage
312 Will County UNO-VEN
oil refining
314 Robinson
Marathon
oil refining
361 Madison
Shell
oil refining97386
386 Marengo
Nissan
engines
401 Will County Mobil Oil
oil refining
403 obile County Shell
oil refining989
405 Kankakee
Henkel
vitamin E

88
88
88
89
89
92
92
92
92
94
95
95
95
97
97
98
89
98

Indianapolis
South Bend
Burns
Clark
Evansville
Fort Wayne
50 Kokomo
GM
73 Indianapolis Eli Lilly
74 Lafayette
Eli Lilly
75 Clinton
Eli Lilly
90 Indianapolis Chrysler
91 Kokomo
Chrysler
92 New Castle Chrysler
127 Lafayette
Caterpillar
148 Lafayette
Subaru-Isuzu
179 Indianapolis Alpine
180 South Bend EWI
239 Midlebury
Coachmen
244 Greenwood Endress&
246 Evansville
Mead Johnson
249 Elkhart
Fairmont
252 Bartholome POnkyo
305 Whiting
Amoco
333 Indianapolis Thompson
379 Rushville
Fugitsu

auto electronics
pharmaceuticals
pharmaceuticals
pharmaceuticals
auto
auto components
auto
tractor engines
auto
audio equip.
auto parts
vehicles
instruments
pharmaceuticals
manufactured
accoustical prods.
oil refining
electronics
auto audio

84
85
85
85
86
86
86
88
89
90
90
92
92
92
93
93
95
96
97

Polk County
Davenport
Cedar
55 Forest City Winnebago
156 Newton
Maytag

auto
appliances

84
89

Kansas City
Sedgwick
84 Kansas
274 McPherson Abbott Labs

auto
pharmaceuticals

85
94

STATUS: (Active
unless otherwise
indicated)

lapsed

INDIAN
22
31
114
133
146
176

lapsed

IOWA
107
133
175

KANSA
17
161

lapsed

CRS-28

STATE

BUSINESS

INDUSTRY

YEAR
APPROVED

Equilon

oil refining

97

lift trucks
auto
home appliances
typewriters &
auto
auto audio
auto parts
oil refining
elec./electronic

84
84
85
86
87
90
90
97
97

New Orleans
Calcasieu Parish
St. Charles
Shreveport
Baton
120 Gramercy
Trans-American oil refining 88
134 Lake
Conoco
oil refining 88
150 Lake
Citgo
oil refining
193 Avondale
Avondale
shipbuilding
194 Westwego
Avondale
shipbuilding
195 Harvey
Avondale
shipbuilding
196 New Orleans Avondale
shipbuilding
210 Lafourche
N.Am.Shipbuild shipbuilding
212 Shreveport AT&T
telecommunicatio
223 New Orleans Equitable
shipbuilding
261 Convent
Star Enterprise oil refining
297 Lafourche
LOOP
crude oil
310 Garyville
Marathon
oil refining
318 St. Bernard Chalmette
oil refining
337 Plaquemine BP
oil refining
343 St. Charles Shell Oil
oil refining
348 Baton
Exxon
oil refining
373 St. Bernard Murphy Oil
oil refining
404 Lockport
Halter Marine
shipbuilding
418 Lockport
Bollinger
shipbuilding

88
88
89
91
91
91
91
91
91
93
94
95
95
95
96
96
96
97
98
98

Bangor
Madawaska
Waterville
202 Madawaska Northern

cosmetics

91

Prince Geoge's County
BWI Airport
Baltimore
61 Sparrow's
Bethlehem
307 Walkersville Rotorex

steel
rotary

85
95

ZONE# SUBZONE #

LOCATION

356 Butler

STATUS: (Active
unless otherwise
indicated)

KENTUCKY
29
47

Jefferson County
Campbell
37 Georgetown Clark
43 Louisville
Ford
86 Jefferson
GE
87 Jefferson
Lexmark
111 Scott
Toyota
177 Walton
Clarion
182 Harrodsburg Hitachi
359 Boyd
Marathan
365 Campton
Ascent

LOUISIANA
2
87
124
145
154

MAINE
58
179
186

MARYLAND
63
73
74

MASSACHUSETTS
27
28

Boston
New

lapsed

CRS-29

STATE

ZONE# SUBZONE #
201

LOCATION

BUSINESS

INDUSTRY

YEAR
APPROVED

Holyoke
7 Fall River
Sterlingwale
apparel
31 Quincy
General
shipyard
32 Lawrencevill Lawrence
textiles
105 Framingham GM
auto
117 New
Codman &Shur. surgical
118 Avondale
Codman &
surgical
119 Randolph
Codman &
surgical
183 Norwood
Polaroid
camera
184 Needham
Polaroid
camera
185 New
Polaroid
camera
186 Waltham
Polaroid
camera
187 Freetown
Polaroid
camera
188 Boston
Polaroid
camera
189 Cambridge Polaroid
camera
410 Quincy
Mass. Heavy
shipbuilding

80
89
84
87
88
88
88
91
91
91
91
91
91
91
98

Sault Ste. Marie
Battle Creek
Detroit
Flint
Kent/Ottawa/Muskegon
St. Clair
10 Romeo
Ford
13 Detroit
Chrysler
19 Wayne
Ford
28 Wixom
Ford
29 Dearborn
Ford
36 Springfield Clark
48 Ypsilanti
GM
49 Pontiac
GM
67 Sterling
Chrysler
94 Flat Rock
Mazda
101 Flint
GM
103 Trenton
Chrysler
123 Midland
Dow
129 Detroit
GM
130 Orion
GM
131 Lansing
GM
161 Detroit
Chrysler
162 Trenton
Chrysler
163 Detroit
Chrysler
164 Detroit
Chrysler
165 Detroit
Chrysler
216 Zeeland
Mead Johnson
303 Wyandotte BASF
362 Detroit
Marathon
377 Sturgis
Abbott
390 Kentwood
Diesel

tractor
auto
auto
auto
auto
lift trucks
auto
auto
auto
auto
auto
auto
chemical
auto
auto
auto
auto
auto
auto
auto
auto
-vitamins/plastics
oil refining
infant formula
fuel injection

81
82
83
83
83
84
84
84
85
86
87
87
88
88
88
88
89
89
89
89
89
92
95
97
97
97

Duluth
Minneapolis/St. Paul
248 St. Peter
Davisco
251 Apple Valley Wirsbo
255 Howard
Am. Feeds &
264 Preston
Wisconsin

dairy prds.
polyethylene
animal feeds
infant formula

93
93
93
94

STATUS: (Active
unless otherwise
indicated)

terminated 89

lapsed

MICHIGAN
16
43
70
140
189
210

MINNESOTA
51
119

terminated 91

lapsed

terminated 92

CRS-30

STATE

BUSINESS

INDUSTRY

YEAR
APPROVED

Plastic
Artesyn

in-line skates
elec. power

96
98

Harrison
Vicksburg/Jackson
115 Escatawpa Moss Pt.
190 Pascagoula Ingalis
237 Harrison
Avondale Ent.
271 Corinth
Cortelo USA
279 Meridian
Peavey Elec.
300 Pascagoula Chevron

shipbuilding
shipbuilding
shipbuilding
phone & computer
audio/acoustical
oil refining

88
91
92
94
94
95

Kansas City
St. Louis
Springfield
20 St.Louis
23 Claycomo
40 Hazelwood
64 Kansas
132 Wentzville
151 Kirksville
152 Kansas City
160 Kansas City
181 Grandview
278 Jefferson

auto
auto
auto
auto
auto
auto components
ag. chemicals
engine parts
sink processing
shoes

83
83
84
93
88
89
89
89
90
94

ZONE# SUBZONE #

LOCATION

345 Lindstrom
414 Redwood

STATUS: (Active
unless otherwise
indicated)

MISSISSIPPI
92
158

MISSOURI
15
102
225

Chrysler
Ford
Ford
-GM
Ortech
Bayer
Kawasaki
Metcals
Florsheim

lapsed

MONTANA
88
187
190

Great Falls
Toote
Butte-Silver Bow

NEBRASKA
19
59

Omaha
Lincoln
8 Lincoln

Kawasaki

motorcycles &

80

Clark
Sparks
52 Reno

Porsche

auto

84

Portsmouth
18 Portsmouth Nashua
33 Colebrook Manchester
232 Newington ABB

office equip
apparel
industrial/nuclear

83
84
92

Morris
Newark/Elizabeth
Salem/Millvi
Mercer
Lakewood
35 Edison
Ford
85 Linden
GM
107 Hazlet
Int'l Flavors

auto
auto
--

84
85
87

NEVAD
89
126

NEW HAMPSHIRE
81

NEW JERSEY
44
49
142
200
235

lapsed

CRS-31

STATE

ZONE# SUBZONE #

LOCATION

BUSINESS

INDUSTRY

YEAR
APPROVED

108 Union
Int'l Flavors
109 S.
Int'l Flavors
153 N.
Squibb
298 Rahway
Merck
319 Linden
Bayway
321 Gloucester Mobil Oil
331 Gloucester CITGO
363 Perth
Chevron
372 Gloucester Coastal Eagle
383 East
Conair
416 Bridgewater Hewlett-Packar

--pharmaceuticals
pharmaceuticals
oil refining
oil refining
oil refining
oil refining
Oil refining
warehouse/distrib
computer-related

87
87
89
95
95
95
96
97
97
97
98

Albuquerqu
Rio Rancho
Dona Ana
58 Albuquerqu SP

pharmaceuticals

84

NY City
Buffalo
Niagara
Orange
Suffolk
Clinton
Onondaga
Jefferson County
JFK Intl. Airport
Ogdensburg
Albany
Monroe
Oneida
26 Webster
Xerox
office equip
59 Waltertown NYAirbrake
-63 Cortland
Smith-Carona electronics
66 N.
GM
auto
93 NY City
Jack Young
-96 Chatauqua CPS Corp.
-106 Onodaga
Chrysler
auto
133 Rochester
Eastman Kodak photography
213 Rochester
ITT
auto electronics
258 New
Bally
shoes
273 Rensselaer Sanophi
pharmaceuticals
292 Rochester
Gleason Corp. gear production
302 Sherrill &
Oneida
tableware
322 Rensselaer BASF
chem.

90
84
85
85
86
86
87
88
91
93
94
95
95
95

Mecklenburg County
Wilmington
Morehead
Raleigh
Lenoir
Fuilford, Forsuth,, etc.
88 Mecklenbur IBM
173 Alamance
Honda

86
90

STATUS: (Active
unless otherwise
indicated)
lapsed
lapsed

NEW MEXICO
110
194
197

NEW YORK
1
23
34
37
52
54
90
109
111
118
121
141
172

NORTH
57
66
67
93
214
230

electronics
lawnmowers

lapsed

lapsed
expired 96
lapsed
lapsed

CRS-32

STATE

ZONE# SUBZONE #

LOCATION

BUSINESS

219 Kernersville Deere-Hitachi
227 Raleigh/Dur IBM
230 Wake
Mallinckrodt
283 Wilson
Merck
328 Goldsboro R.G. Barry
335 Whitsett
Lucent
378 Yadkinville Unifi
NORTH DAKOTA
103

INDUSTRY

YEAR
APPROVED

hydraulic
info processing
pharmaceuticals
pharmaceuticals
footwear &
telecommunicatio
polyester yarn

92
92
92
94
96
96
97

Toledo
Cleveland
Butler
Dayton
Clinton
Franklin
Findlay
Akron/Canto
5 Hamilton
GE
jet engines
6 Union City Honda
motorcycles
34 Toledo
Jeep
auto
44 Lorain
Ford
auto
65 Lordstown GM
auto
102 Norwood
GM
auto
110 Shelby
Honda
car/motorcycle
121 Findlay
Cooper Tire & tires
128 Cincinnati
Nine West
shoes
157 Dayton
GM
electric motors
158 Kettering
GM
auto parts
166 Dayton
Chrysler
auto parts
167 Perrysburg Chrysler
auto parts
168 Sandusky
Chrysler
auto parts
169 Van Wert
Chrysler
auto parts
170 Toledo
Giant Products industrial pumps
203 Richwood
Wascator Mfg. washing machines
236 Ottawa
W.C. Wood
freezers
254 Avon Lake Ford
motor vehicles
257 Euclid/Ment Lincoln Electric arc welding equip.
259 McComb
Consolidated
food
268 Bedford
Mr. Coffee
small appliance
280 Valley View Picker
medical
325 Grove City Pier 1
distribution
326 Bedford
Ben Venue
pharmaceuticals
338 Toledo
BP Oil
oil refining
344 Euclid
Motch
machinery
358 Stark/Allen Marathon
oil refining
366 Springboro pioneer
auto audio
387 Columbus
Abbott
infant formula
417 Beverly
Globe
ferroalloys
424 Columbus
Lucent
telecommunicatio
425 Lima
Clark USA
oil refining

79
79
84
84
85
87
87
88
88
89
89
89
89
89
89
90
91
92
93
93
93
94
94
96
96
96
96
97
97
97
98
98
98

Grand Forks

OHIO
8
40
46
100
101
138
151
181

OKLAHOMA
53
106
164

Rogers
Oklahome
Muskogee

STATUS: (Active
unless otherwise
indicated)

CRS-33

STATE

ZONE# SUBZONE #
227

LOCATION

Durant
51 Oklahome
240 Oklahome
394 Lincoln

BUSINESS

INDUSTRY

GM
auto
Ted Davis Mfg. voice aoil motors
ARCO Pipe
crude oil

YEAR
APPROVED

STATUS: (Active
unless otherwise
indicated)

84
92
98

OREGO
45
132
184
206

Portland
Coos
Klamath
Medford-Jackson County
9 Multnomah Beall Pipe
171 Portland
AIM
207 Portland
Alcatel
221 Pendleton
Continental
247 Tualatin
Tofle USA

fiberoptic cable
food
stainless steal

80
90
91
92
92

Pittston
Allegheny County
Philadelphia
Berks
3 Westmorela VW
4 Harrisburg Olivetti
21 Landsdale Ford
142 Allegheny
Verosol USA
282 West Point Merck
285 Riverside
Merck
342 Philadelphia Sun Company
369 Delaware
Tosco

auto
typewriters,
auto
window shade
pharmaceuticals
pharmaceuticals
oil refining
oil refining

77
78
83
89
94
94
96
97

Mayaguez
Guyanabo
Ponce
15 Penuelas
CORCO
217 Humacao
Bristol-Myers
218 Barceloneta Bristol-Myers
245 Caguas
Searle
266 Barceloneta Searle
267 Cidra
SB Pharmco
294 Arecibo
Merck
295 Barceloneta Merck
316 Guayama
IPR
317 Carolina
IPR
360 San Juan
Baxter Caribe
371 Skagit Cnty. PR Sun oil
384 Cidra
PepsiCo
423 San Juan
Pfizer

oil refining
pharmaceuticals
pharmaceuticals
pharmaceuticals
pharmaceuticals
pharmaceuticals
pharmaceuticals
pharmaceuticals
pharmaceuticals
pharmaceuticals
pharmaceuticals
oil refining
concentrate
pharmaceuticals

82
92
82
92
94
94
95
95
95
95
97
97
97
98

auto
auto electronics

84
91

deactivated 83
lapsed

PENNSYLVANIA
24
33
35
147

PUERTO RICO
7
61
163

RHODE ISLAND
105

Providence

SOUTH
21
38
127

Dorchester Cnty
Spartanburg Cnty
West
53 Charleston Porsche
208 Anderson
AUTECS

deactivated 81

CRS-34

STATE

ZONE# SUBZONE #

LOCATION

BUSINESS

235 Goose
Haarmann &
272 Spartanburg BMW
399 Goose
Bayer Corp
SOUTH DAKOTA
220

INDUSTRY

YEAR
APPROVED

chemicals
auto
rubber

92
94
98

truck/auto
microwave ovens
energy
energy
microwave ovens
auto
-pharmaceuticals
industrial
typewriters/word
room
equip. parts dist.

82
83
84
84
84
90
91
95
95
95
95
98

Sioux Falls

TENNESSEE
77
78
134
148
204
223

Memphis
Nashville
Chattanoog
Knoxville
Tri-City
Memphis
14 Symnra
27 Lebanon
38 Hartsville
39 Phipps
45 Memphis
175 Maury Cnty.
192 Hawkins
289 Bristol
301 Carter Cnty.
308 Bartlett
311 Columbia
413 Ripley

Nissan
Toshiba
TVA Nuclear
Global Power
Sharp
Saturn
Form Rite
SmithKline
Soemens
Brother Ind.
Columbia
Komatsu

TEXAS
12
36
39
62
68
80
84
94
95
96
97
113
115
116
117
122
149
150
155
156
165
168
171
178
183
196
199
234

McAllen
Galveston
Dallas/Fort Worth
Brownsville
El Paso
San Antonio
Harris
Webb
Starr County
Maverick
Val Verde County
Ellis County
Beaumont
Jefferson County
Orange
Corpus
Freeport
El Paso
Victoria & CalhounCounties
Weslaco
Midland
Dallas/Fort Worth
Liberty
Presidio
Austin
Fort Worth
Texas City
Gregg
62 Jefferson
Bethlehem
76 Corpus Ch. Coastal St.

85
oil refining

STATUS: (Active
unless otherwise
indicated)

CRS-35

STATE

ZONE# SUBZONE #

LOCATION

BUSINESS

INDUSTRY

77 Corpus Ch. Koch Refining oil refining
78 Corpus Ch. Trifinery
oil refining
79 Corpus Ch. Gulf Marine
oil refininh
80 Corpus Ch. Berry
-81 Corpus Ch. CC Distributing -82 Corpus Ch. Compressors
-83 Corpus Ch. Hitox
-122 Athens
Harvey Inds.
TVs
124 Victoria
Safety Railway freight car repair
125 Victoria
Safety Steel
freight car repair
135 Corpus
Citgo
oil refining
136 Nueces
Valero
oil refining
139 Weslaco
McManus
food processing
140 Weslaco
FGulf De Bruyn food processing
141 Weslaco
Sundor
food processing
143 Corpus Ch. Reynolds
alumina
144 Houston
Hughes Tool
drilling tools
145 Houston
Texas Steel
heat-treat oil
176 LaPorte
DuPont
hydrofluoric acid
198 Houston
United General hand tools
199 San Antonio Bausch & Lomb sunglasses
200 San Antonio Colin Medical
medical equip,
201 San Antonio Friedrich A/C & air conditioners
205 Calhoun
Alcoa
alumina/aluminum
206 Houston
Gulf Coast
oil refining
209 Nueces
Koch Refining oil refining
211 Arlington
GM
auto
214 Houston
Calero Refining oil refining
215 Houston
Goodman Mfg. -225 Harris
Shaffer
oil drilling equip.
241 Austin
Dell Computer electronics
242 Harris
Tuboscope
steel tube prds.
260 Harris
Shell Oil
oil refining
262 Port Arthur Star Enterprise oil refining
263 Wylie
Sanden
auto a/c
265 Houston
Dril-Quip
oil field equip
287 Houston
Hydril
oil field equip
288 Houston
Tadiran
telecom. prds.
290 Tx City
Amoco
oil refining
291 Freeport
BASF
chemicals
309 Jefferson
Fina
oil refining
313 Jefferson/Li Mobil Oil
oil refining
315 Freeport
JHoffnam-LaRo pharmaceuticals
320 Harris
Crown Central oil refining
324 Mansfield
Pier1
distribution
327 San Angelo R.G. Barry
footwear &
339 Texas City Marathon
oil refining
341 Harris
Exxon
oil refining
349 Jefferson
Clark
oil refining
357 Texas City Valero
oil refining
374 Jefferson
USDOE Oil
crude oil shortage
381 Brazoria
Phillips
oil refining
388 Richardson Fossil Partners watches, etc.
389 Dallas
B&F System
consumer prds.
395 Brazoria
Seaway
crude oil
396 Texas City Seaway
crude oil
402 Harris
Lyondell-Citgo oil refining
409 Harris
Equistar
petrochemicals

YEAR
APPROVED
95
85
85
85
85
85
85
88
88
88
88
88
88
88
89
88
89
89
90
91
91
91
91
91
91
91
91
91
91
92
92
92
93
93
93
94
95
95
95
95
95
95
95
95
96
96
96
96
96
97
97
97
97
97
98
98
98
98

STATUS: (Active
unless otherwise
indicated)

expired 91
expired 91

lapsed
lapsed

lapsed

CRS-36

STATE

ZONE# SUBZONE #

LOCATION

YEAR
APPROVED

BUSINESS

INDUSTRY

Ultrak
Amoco

closed circuit TV
petrochemicals

98
98

Pedigree
Wyeth

apparel

82
90

Suffolk
Wash. Dulles Intl. Airport
Culpeper
Richmond
146 Va. Beach
Stihl
228 Culpeper
ITT Teves
229 Culpeper
Rochester
253 Newport
NN
284 Elkton
Merck & Co
305 Whiting
Amoco
367 Altavista
Abbott
406 Richmond
Hewlett-Packar

chain saw/power
auto brake comp.
cable
shipbuilding
pharmaceuticals
oil refining
formula/nutritional
computer-related

89
92
92
93
94
95
97
98

Seattle
Everett
Tacoma
Cowlitz
Whatcom
Whatcom
Whatcom
Whatcom
Grays
Yakima
Moses Lake
Tacoma
Olympia
Spokane
126 Tacoma
Tacoma Boat.
191 Hoquiam
Lamb-Grays
270 Arlington
West-Coast
370 Skagit Cnty. Equilon

shipbuilding
-wood building
oil refining

88
91
94
97

Wood/Jackson Counties
Charleston
397 Buffalo
Toyota

auto engines

98

Milwaukee
Brown
11 Kenosha
12 Manitowac
68 Janesville
69 Oak Creek

auto
piston rings
auto
auto electronics

81
81
85
85

421 Lewisville
422 Brazoria

STATUS: (Active
unless otherwise
indicated)

UTAH
30

Salt Lake

55
91

Burlington
Newport
17 St. Albans
172 Georgia

VERMONT

VIRGINI
20
137
185
207

lapsed

WASHINGTON
5
85
86
120
128
129
130
131
173
188
203
212
216
224

WEST VIRGINIA
228
229

WISCONSIN
41
167

Chrysler
Muskegon
GM
GM

lapsed

CRS-37

STATE

ZONE# SUBZONE #

LOCATION

71 Sturgeon
97 Milwaukee
238 Blue
352 Hudson
391 Osceola
393 Plymouth
WYOMING
157

Casper

BUSINESS

INDUSTRY

Bay
shipbuilding
Ambrosia
-Stauffer
cheese prods
Robin Mfg.
small engines
Polaris
small engines
Sargento Foods cheese prcessing

YEAR
APPROVED
85
87
92
96
97
98

STATUS: (Active
unless otherwise
indicated)

expired 91

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/crs%3ARL30268. Public record. Not legal advice.
