Section 122 interacts with FTZ status differently for PF vs. NPF goods. PF goods admitted before February 24, 2026 (Section 122 effective date) are not subject to Section 122 on later consumption – rates locked at admission. NPF goods admitted before that date but withdrawn after pay Section 122. Re-exports from NPF avoid Section 122 entirely.
This guide covers FTZ and Section 122 – Status-Specific Implications. A Foreign Trade Zone is a U.S. zone where imported goods can be admitted, processed, and re-exported without paying customs duty.
For SMB importers, the practical implementation depends on volume, sector, and operational structure.
PF goods admitted before Feb 24, 2026
Rates locked at admission. Section 122 not applied on later consumption (admission date predates the surcharge).
NPF goods admitted before Feb 24, withdrawn after
NPF follows consumption-entry-date rates. Section 122 applies on withdrawal.
Re-exports from NPF
Goods re-exported never enter U.S. consumption – no Section 122 paid.
Goods admitted after Feb 24
PF locks at admission rate (Section 122 included). NPF follows consumption-entry-date rate (Section 122 included).
Frequently asked questions
When does this apply?
For SMB importers with active duty exposure or those evaluating mitigation options.
What documentation is required?
Standard CBP forms plus topic-specific supporting records. We review documentation as part of typical engagements.
What is the timeline?
Simple cases 2-4 weeks; complex setups 8-16 weeks.
What does this cost?
Project work: $5,000-$25,000 depending on complexity. Ongoing retainer for active operations.
How do I begin?
Book a 15-minute scoping call. We confirm fit and scope before any engagement.
Get started
Run a fixed-fee FTZ ROI analysis for your operation. $2,500-$5,000.