FTZ Subzone Approvals and Samsung's Texas Application

Three FTZ subzones have gained approval for facilities in Massachusetts, Wisconsin, and Missouri, while a proposed Samsung Electro-Mechanics subzone advances in Texas. The developments create immediate activation, admission, and compliance considerations for the companies involved, their zone operators, customs brokers, and suppliers moving foreign-status merchandise.

Three Companies Receive FTZ Subzone Approval

The Foreign-Trade Zones Board approved subzone status for Persimmon Technologies Corporation, Tekni-Plex Flexibles LLC, doing business as TekniPlex Healthcare, and BASF Agricultural Solutions US LLC. Each authorization connects a company-specific facility or group of facilities to an existing general-purpose foreign-trade zone and its grantee.

Persimmon, TekniPlex, and BASF Subzones

Persimmon Technologies received approval for Subzone 27U at 35 Crosby Road in Bedford, Massachusetts. The site operates under FTZ 27, whose grantee is the Massachusetts Port Authority. The application was docketed on August 28, 2026, and approved on November 2, 2026. No production activity was requested as part of the application.

TekniPlex Healthcare received approval for Subzone 266C at 6002 Femrite Drive in Madison, Wisconsin. The subzone falls under FTZ 266, with Dane County serving as grantee. Its application was docketed on June 1, 2026, and approved on October 29, 2026.

BASF Agricultural Solutions received approval for Subzone 102I covering facilities in Fenton and Palmyra, Missouri. The sites operate under FTZ 102, whose grantee is the St. Louis County Port Authority. The application was docketed on May 11, 2026, and approved on October 29, 2026.

These approvals establish subzone status, but they do not by themselves authorize the immediate admission of merchandise under FTZ procedures. The operators must generally complete U.S. Customs and Border Protection activation requirements before using the approved sites for zone activity. Any activity beyond the scope of the approved applications, particularly production, may require additional authorization.

Parent Zone Activation Limits Still Apply

Each subzone remains subject to the activation limit of its parent zone. FTZ 27 has a 129-acre activation limit, FTZ 266 has a 648-acre limit, and FTZ 102 has a 2,000-acre limit. Grantees and operators must account for these limits when determining how much approved acreage can be activated at a given time.

Samsung Electro-Mechanics Advances a Texas Application

Samsung Electro-Mechanics America has applied for subzone designation at 1200 Fulghum Road in Wilmer, Texas. The proposed 0.69-acre site would operate under FTZ 168, with Metroplex International Trade Development Corporation serving as the grantee.

Public Comment and Rebuttal Deadlines

The application was docketed on October 28, 2026. Interested parties may submit comments through December 14, 2026, followed by a rebuttal period that runs through December 28, 2026. Trade compliance teams evaluating the proposal should distinguish between operational competition, public-interest considerations, and the technical eligibility of the proposed site.

No production authority has been requested at this stage. If approved as filed, the subzone would generally be limited to activities consistent with the application and applicable FTZ procedures. A later decision to conduct manufacturing or production could require a separate notification or application, depending on the proposed activity.

The application is also subject to FTZ 168's existing activation limit. Approval would therefore establish the site's eligibility for subzone treatment, but activation would still depend on available acreage, coordination with the grantee, and CBP authorization.

Approval Is Not the Same as Activation

The distinction between designation and activation is operationally important. The FTZ Board determines whether a site may receive zone status, while CBP generally controls activation and supervises zone procedures at the port level. Until activation is complete, the operator should not admit merchandise or represent the facility as an active FTZ site.

Samsung Electro-Mechanics, its grantee, and prospective service providers should use the review period to align inventory controls, physical security, admission procedures, recordkeeping, and broker responsibilities. Early planning can reduce delays between a potential approval and the start of authorized zone operations.

Compliance and Duty Planning for Subzone Users

An approved and activated subzone can provide meaningful customs benefits, but those benefits depend on disciplined inventory management and accurate transaction controls. Companies should evaluate the complete merchandise lifecycle, including admission, storage, manipulation, production, entry into U.S. commerce, transfer, and export.

Admission and Broker Controls

Merchandise generally cannot enter FTZ status until CBP has activated the site and the appropriate admission documentation has been accepted. Brokers should confirm the site's active status with the operator rather than relying solely on the FTZ Board's approval date.

The parties should also define who is responsible for admission data, status designations, tariff classification, valuation, country of origin, partner government agency requirements, and reconciliation between physical inventory and zone records. Suppliers shipping foreign-status goods need clear routing instructions because delivery to an approved address does not automatically create FTZ treatment.

Foreign merchandise may generally be admitted in privileged foreign, non-privileged foreign, or another permitted status, depending on the transaction. The selected status can affect later duty calculations, particularly when merchandise is transformed or entered into U.S. commerce. Status decisions should therefore be supported by documented tariff and supply chain analysis rather than treated as routine clerical choices.

FTZ Duty Deferral Is Not Duty Drawback

FTZ treatment and duty drawback can both reduce customs costs, but they operate at different points in the import-export cycle. A foreign-trade zone generally defers duty while foreign merchandise remains in the zone. If that merchandise is exported directly from the zone without entering U.S. commerce, U.S. customs duty is generally not paid.

Duty drawback typically involves the recovery of eligible duties, taxes, and fees that were previously paid on imported merchandise connected to a qualifying export or destruction. When no duty was paid because merchandise remained in FTZ status and was exported from the zone, there is generally no duty available to recover through drawback.

A company can still have separate drawback opportunities outside its FTZ flows. For example, merchandise entered into U.S. commerce with duty paid may later support a qualifying drawback claim. Compliance teams should segment FTZ and duty-paid transactions carefully, prevent duplicate benefits, and preserve the records needed to substantiate each program independently.

Frequently Asked Questions

What Is an FTZ Subzone?

An FTZ subzone is a site approved for a specific company or operation and connected to an existing foreign-trade zone. It is typically used when a facility cannot practicably operate within the general-purpose zone's existing site structure. The parent zone's grantee maintains an important administrative role.

Can a Company Use FTZ Procedures Immediately After Approval?

Generally, no. FTZ Board approval establishes zone designation, but the site must typically be activated by CBP before merchandise can be admitted under FTZ procedures. Activation usually requires coordination concerning security, inventory controls, recordkeeping, operating procedures, and the scope of authorized activity.

What Does an Activation Limit Mean?

An activation limit controls the amount of acreage within a zone that may be active at one time. Approved acreage and activated acreage are not necessarily the same. A subzone can receive approval while remaining subject to the parent zone's available activation capacity and activation management decisions.

Does Subzone Approval Include Production Authority?

Not automatically. Storage and distribution authority does not necessarily permit production. When an application does not request production authority, the operator should generally limit activity to the approved scope. Proposed manufacturing or production may require additional FTZ Board review before it begins.

Can Merchandise Exported From an FTZ Generate Drawback?

Merchandise exported directly from an FTZ generally has not incurred U.S. customs duty, so there is typically no paid duty to recover. Drawback may remain available for separate duty-paid import transactions that satisfy the applicable eligibility, export, timing, and recordkeeping requirements.

What Should Customs Brokers Verify Before Handling FTZ Shipments?

Brokers should confirm that the specific site is activated, identify the operator and grantee, verify the intended merchandise status, and understand the admission process. They should also clarify responsibilities for classification, valuation, origin, agency data, inventory reporting, transfers, withdrawals, and subsequent entries into U.S. commerce.

How Stable Software Can Help

Supporting Broker-Led Drawback Programs

FTZ duty deferral and duty drawback require separate eligibility analyses and transaction controls. Customs brokers serving importers with both zone and duty-paid flows need to distinguish merchandise exported without duty payment from imports that may support a valid drawback claim.

Stable Software offers DrawbackAI, flat-license duty drawback software that U.S. customs brokers can white-label for importer clients and use to file claims under their own filer codes. Stable Software charges a flat software license and never takes a percentage of the refund. Brokers evaluating how duty drawback fits alongside their clients' FTZ strategies can learn more about Stable Software's approach for customs brokers.

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