April 2021 — Question 79

Based on the information below, how long will Plaid Christmas Tree Inc. be REQUIRED to maintain records identified within 19 CFR § 162.1(a)? The entity Plaid Christmas Tree Inc. (Plaid) seeks flexibility in its manufacturing operations and the ability to delay entry procedures and payments of duties on its foreign merchandise until those goods enter CBP territory for domestic consumption. At which point, Plaid will have the choice of paying duties at the rate of either the original foreign materials or the finished product. To obtain this flexibility, Plaid intends to open and operate a Foreign Trade Zone (FTZ) in a warehouse next to their existing parts/assembly facility. Prior to making further FTZ arrangements, Plaid is ensuring they understand their obligations to retain records (recordkeeping), if any exist, as the operator of an FTZ.

• APlaid does not need to maintain the records because their licensed Customs Broker is required to maintain the records on their behalf.
• BThe consignee of the merchandise shall keep all records pertaining to the merchandise for 2 years from the date of entry.
• CRecords must be maintained by Plaid for five years following the removal of the merchandise from the zone.✓ CBP's answer
• DThe operator is only required to maintain the packing lists for a period of 60 calendar days from the end of the release or conditional release of the merchandise.
• EForeign Trade Zone documents are not listed within the (a)(1)(A) list and are therefore exempt from CBP’s recordkeeping requirements.