Foreign Trade Zones at Airports
This article examines Foreign Trade Zone (FTZ) operations at U.S. airports, including the federal regulatory framework, grantee and operator structures, economic benefits, fee revenue, and financial dimensions. Analysis draws from 19 U.S.C. §§ 81a–81u (Foreign-Trade Zones Act of 1934), International Trade Administration (ITA) guidance, FTZ Board Annual Reports, published Zone Schedules from airport-affiliated grantees, and tariff documentation from USTR. All data is current as of March 6, 2026.
Foreign Trade Zones are designated areas where foreign and domestic merchandise may be imported, stored, processed, or manufactured without customs duties or ad valorem taxes until goods enter U.S. commerce or are re-exported. As of 2024, 262 FTZ projects and 398 subzones operate in the United States (per FTZ Board's 2024 Annual Report), handling $964 billion in merchandise (up from $949 billion in 2023) and employing 543,000 persons. Airport authorities serve as grantees at facilities including DFW (FTZ 39), Miami (FTZ 281), Huntsville (FTZ 83), and Columbus (FTZ 138), generating non-aeronautical fee revenue ranging from $2,000 to $20,000 per operator/site annually (e.g., Columbus FTZ 138 per CRAA's November 2023 Fee Schedule) while extending economic development influence to regional suppliers through Alternative Site Framework (ASF) service areas.
The FTZ Program
A Foreign Trade Zone (FTZ) is a designated area within or adjacent to a U.S. port of entry where foreign and domestic merchandise is treated as being outside U.S. customs territory for tariff purposes. Goods may be imported into an FTZ, stored, manipulated, manufactured, or re-exported without being subject to customs duties or ad valorem taxes until they enter U.S. commerce — or without any duty at all if re-exported (Source: 19 USC §§ 81a–81u, Foreign-Trade Zones Act of 1934; U.S. Department of Commerce, International Trade Administration, "About FTZs").
The program is administered by the Foreign-Trade Zones Board, which consists of the Secretary of Commerce (chair) and the Secretary of the Treasury. U.S. Customs and Border Protection (CBP) supervises day-to-day zone operations under 19 CFR Part 146.
FTZ Activity (Calendar Year 2024)
As of the FTZ Board's 2024 Annual Report to Congress:
| Metric | CY 2024 | CY 2023 |
|---|---|---|
| Total merchandise received | $964 billion | $949 billion |
| Exports from FTZs | $134 billion | $149 billion |
| Persons employed in FTZ operations | 543,000 | 550,000 |
| Active production operations | 381 | 374 |
As of the FTZ Board's 84th Annual Report (2024), there are more than 260 FTZ projects and nearly 400 subzones operating across the United States. Industries with the highest value of FTZ production activity (based on $964 billion in merchandise in CY 2024) include pharmaceutical, oil refining, automotive, electronics, and machinery/equipment sectors (per FTZ Board's 2024 Annual Report).
FTZ Structure: Grantees, Operators, and Users
Grantee: A public corporation or private not-for-profit corporation to which the FTZ Board has granted the privilege of establishing, operating, and maintaining a foreign trade zone. Public entities that may serve as grantees include municipalities, public agencies, political subdivisions, or corporate municipal instrumentalities. The grantee must operate the zone as a "public utility" — providing uniform treatment under like conditions, with fair and reasonable charges (Source: 19 USC § 81a(e)–(h)).
Operator: A corporation, partnership, or person that operates within a zone or subzone under agreement with the grantee. The operator must obtain CBP approval and post an FTZ Operator's Bond.
User: An entity that uses the zone for storage, handling, processing, or manufacturing of merchandise in zone status. In subzones, the operator and user are frequently the same entity.
Zone Schedule: Each grantee is required to publish a Zone Schedule — the mandatory document containing rules, regulations, and all fees charged for zone services and privileges.
Airport Authorities as FTZ Grantees
Airport authorities serve as FTZ grantees at multiple U.S. airports. Airports function as FTZ grantees because they are ports of entry with CBP presence, cargo infrastructure, and proximity to manufacturing and distribution activity — each of which the ITA requires for FTZ designation eligibility.
Dallas Fort Worth International Airport — FTZ No. 39
The Dallas/Fort Worth International Airport Board is the grantee of FTZ No. 39, approved by the FTZ Board on August 17, 1978. FTZ 39 received over $16 billion in merchandise in calendar year 2023 (Source: DFW Airport, "U.S. Foreign Trade Zone No. 39").
DFW's FTZ operates in three configurations:
- On-airport: 2,400 acres on-airport property pre-designated as FTZ, with 91 buildings containing 21 million square feet of warehouse and distribution space
- Off-airport pre-designated site: 644 acres at Railhead Industrial Park in Fort Worth
- Company-specific sites: DFW sponsors company-specific FTZ designations throughout the Dallas–Fort Worth metropolitan area — including Sanden, Fossil Partners, and Safran Helicopter Engines
Under the Alternative Site Framework (ASF), DFW's FTZ service area covers eight counties (6,971 square miles), allowing expedited FTZ Board approval for company-specific designations within that geography.
Miami International Airport — FTZ 281 Magnet Site
Miami-Dade County's FTZ 281, with PortMiami as the grantee, designated Miami International Airport's entire 3,200-acre land parcel as an FTZ magnet site. The FTZ Board granted final approval in 2018. In April 2023, LATAM Airlines Group became MIA's first approved FTZ operator, shipping aircraft parts from Chile to its MIA maintenance facility for repair and return to South America without paying federal import duties. LATAM's operation uses the FTZ's re-export duty elimination benefit: parts imported into the zone for repair and then re-exported to South America never enter U.S. customs territory (Source: MIA News, "LATAM Group Becomes First MIA Foreign Trade Zone Operator," April 16, 2023).