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Foreign Trade Zones & Warehouses

April 2018 — Question 70

Which of the following terms describe the association of final products removed from or consumed within a petroleum refinery foreign trade subzone to feedstock admitted into the petroleum refinery foreign trade subzone in the current or prior manufacturing period?

Why this answer

The petroleum refinery subzone rules in subpart H of 19 CFR part 146 define attribution as exactly this association: tying final products removed from or consumed within the refinery subzone back to the feedstocks admitted in the current or a prior manufacturing period. Producibility is the related but distinct concept addressing whether a given final product could have been produced from a particular feedstock under industry standards, relative value is an apportionment tool, and privileged foreign status is an inventory status election rather than an accounting association. Producibility tempts most because it appears in the same subpart and works hand in hand with attribution. Watch for: Choosing producibility, the standard used in performing attribution, instead of attribution itself.

Original CBLE Simulator explanation — the question and key above are CBP's; this analysis is ours. Verify against the current edition before relying on it in practice.

CBP's cited authority

§ 19 CFR 146.92(a)(c)(d)(h)(i) & 141.41(a)

Answer and citations as published in CBP's official answer key for the April 2018 examination.

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