DWU CONSULTING

March 2026

Foreign Trade Zones at Airports

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. The largest industries by FTZ production activity include pharmaceutical, oil refining, automotive, electronics, and machinery/equipment sectors.

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. The airport's status as a port of entry, its CBP presence, its cargo infrastructure, and its proximity to manufacturing and distribution activity make airports natural anchor points for FTZ designations.

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).

Huntsville International Airport — FTZ No. 83

The Huntsville-Madison County Airport Authority is the grantee of FTZ No. 83, which serves the Port of Huntsville. The airport authority markets the FTZ as part of its intermodal cargo platform, emphasizing duty deferral, duty elimination on re-exports, inverted tariff benefits for manufacturing, and no duty on waste or scrap (Source: Port of Huntsville, "Foreign Trade Zone No. 83").

Columbus Regional Airport Authority — FTZ 138

The Columbus Regional Airport Authority (CRAA), operator of John Glenn Columbus International Airport and Rickenbacker International Airport, is the grantee of FTZ 138. CRAA publishes a fee schedule with tiered application fees based on site acreage (Source: CRAA, "Fee Schedule," updated November 27, 2023).

Economic Benefits of FTZs

FTZ procedures provide several categories of tariff and tax benefits:

Duty deferral: Customs duties are not assessed on foreign merchandise while it remains in the zone. Duties are paid only when goods leave the zone and enter U.S. commerce. Companies holding imported inventory in an FTZ align duty payments with their sales cycle rather than with the date of importation.

Duty elimination on re-exports: Goods that are imported into an FTZ and subsequently re-exported without entering U.S. commerce are not subject to duty at all. This benefit applies to goods in their original form and to goods processed or manufactured in the zone and then exported. LATAM's MIA operation — importing aircraft parts for repair and re-exporting to South America — illustrates this benefit.

Inverted tariff (duty reduction): With FTZ Board manufacturing authority, a company may elect to pay duty at the rate applicable to the finished product rather than the higher rate applicable to imported components. No duty is assessed on U.S. value-added during zone production. This benefit is available when the finished product's tariff rate is lower than the component rate.

No duty on waste, scrap, or destroyed goods: Merchandise that is scrapped, has no residual commercial value, or is destroyed within the zone under CBP supervision is not subject to duty.

No state or local ad valorem personal property tax: Foreign-status inventory within an FTZ is generally exempt from state and local personal property tax. Domestic inventory held for export may also be exempt.

Weekly entry consolidation: Rather than filing a customs entry for each individual shipment, FTZ operators may file a single weekly entry covering multiple shipments. This consolidation reduces Merchandise Processing Fees (MPF) — a per-entry fee of 0.3464% of the value of merchandise (minimum $31.67, maximum $614.35 per entry as of 2024) — by aggregating multiple transactions into one.

FTZ Grantee Fee Revenue

FTZ grantees, including airport authorities, recover their administrative costs through fees charged to operators and users. Each grantee publishes a Zone Schedule that sets out its fee structure:

Fee Type	Columbus (CRAA) FTZ 138 (Nov. 2023)	Dayton FTZ 100 (Jan. 2000)	San Diego FTZ 153
Application fee (new site)	$7,500–$20,000 (by acreage)	$10,000 (subzone)	$2,500–$3,500
Activation fee	Included in application	Included in annual	$1,200–$1,500
Annual operator fee	$3,750–$7,500 (by acreage tier)	$10,000 (subzone or GP operator)	Varies

Source: CRAA, Fee Schedule, November 2023; Greater Dayton FTZ 100, Zone Fee Schedule; San Diego FTZ 153, Zone Schedule.

In addition to grantee fees, the FTZ Board charges separate filing fees for applications. As of 2023, the Board fee for a general-purpose zone expansion (new magnet site) was $1,600.

For airport authorities, FTZ grantee fees represent non-aeronautical revenue. The scale of that revenue depends on the number of active operators, the fee schedule, and the volume of zone activity within the grantee's project.

Current Tariff Environment and FTZ Relevance

The period from 2018 through 2026 has seen sustained tariff escalation on imported goods:

• Section 301 tariffs on China: Originally 10%–25% on Lists 1–4A (2018–2019); modified in September 2024 with increases to 25%–100% across 14 product groups including EV batteries (100%), semiconductors (50%), solar cells (50%), and steel/aluminum (25%) — with additional increases taking effect in 2025 and 2026 (Source: USTR, "Section 301 Modifications Determination," September 12, 2024)
• Section 232 tariffs on steel and aluminum: 25%–50% on steel and aluminum products, with scope expanded in August 2025 to cover additional HTS codes (Source: Dimerco, "US Tariff Update," January 13, 2026)

FTZs do not eliminate Section 301, Section 232, or other special tariffs on goods that ultimately enter U.S. commerce. However, FTZ procedures provide three mechanisms that interact with elevated tariff rates:

1. Duty deferral: Companies defer paying Section 301/232 duties until goods leave the zone, improving cash flow on high-tariff imports
2. Duty elimination on re-exports: If imported goods are processed in the zone and re-exported, no Section 301/232 duties are ever assessed
3. Inverted tariff on manufacturing: Where a finished product carries a lower duty rate than its imported components, FTZ manufacturing authority allows the company to elect the lower rate

The 2023 FTZ Board Annual Report noted that 68% of shipments received at zones involved domestic-status merchandise — indicating that FTZ activity is not solely an import-duty play but reflects domestic manufacturing operations with domestic inputs alongside foreign inputs. The CY 2024 increase in total merchandise received — from $949 billion to $964 billion — occurred during a period of elevated tariff rates, demonstrating that tariff escalation has driven increased use of FTZ procedures.

The Alternative Site Framework (ASF)

The ASF, adopted by the FTZ Board in 2012, streamlined the process for designating new FTZ sites within a grantee's defined service area. Under the traditional (pre-ASF) process, each new site required a full FTZ Board application. Under the ASF, eligible grantees may request "usage-driven" site designations — company-specific FTZ status at any location within the service area — through an expedited administrative process (Source: ITA, "About FTZs").

For airport grantees, the ASF expands the geographic scope of the FTZ project beyond the airport's physical boundaries. DFW's eight-county, 6,971-square-mile service area allows the airport board to sponsor FTZ designations throughout the Dallas–Fort Worth metropolitan area — generating grantee fee revenue from off-airport companies and extending the airport's economic development role.

FTZ Activation and Compliance

Once a zone site is approved by the FTZ Board, three steps are required before FTZ procedures can begin (Source: ITA, "About FTZs"):

1. Operating Agreement: The operator executes an operating agreement with the grantee
2. CBP Activation: The operator applies to the local CBP Port Director for activation. CBP reviews include background checks, a written procedures manual, posting of an operator's bond, and review of site security and inventory control methods
3. Annual Reporting: Once activated, operators report zone activity annually through the FTZ Board's Online FTZ Information System (OFIS)

CBP oversight is conducted primarily through audit-based compliance reviews and spot checks rather than continuous on-site monitoring.

Financial Dimensions for Airport Operators

For airport authorities serving as FTZ grantees, the program creates several financial and operational touchpoints:

• Non-aeronautical revenue: Grantee fees (application, activation, annual) from operators and users are non-aeronautical revenue. The fee levels — ranging from $2,000 to $20,000 per operator/site per year based on published Zone Schedules — are modest on a per-operator basis but may aggregate to a meaningful revenue line for grantees with multiple active operators
• Cargo development: FTZ status is a competitive advantage in attracting cargo tenants. MIA's 3,200-acre magnet site designation is positioned as a tool for airline and cargo company recruitment. DFW's on-airport designation of 21 million square feet of warehouse space as FTZ-eligible creates a differentiated value proposition for logistics tenants
• Economic development role: Through ASF service areas, airport authorities extend their FTZ grantee role into the regional economy. DFW's sponsorship of company-specific FTZs in the Dallas–Fort Worth metropolitan area positions the airport board as a regional economic development entity, beyond its aeronautical mission
• Public utility obligation: The statutory requirement to operate the zone as a public utility — with fair, reasonable, and uniform charges — constrains pricing flexibility. Fee schedules are subject to FTZ Board oversight, and discriminatory pricing among similarly situated operators is prohibited