Foreign Trade Reporting Corrections and Clarifications
Summary
On August 14, 2025, the Census Bureau published a final rule in the Federal Register entitled, "Foreign Trade Regulations (FTR): Clarification of Filing Requirements Regarding In-Transit Shipments and Other FTR Provisions". This document referenced incorrect amendatory language in the List of Subjects in 15 CFR part 30 section.
Compliance Requirements
- #1
Split Shipments should be referenced as such on the manifest in accordance with provisions contained in § 30.28, Split Shipments. The notation should be easily identifiable on the manifest. It is preferable to include a reference to a split shipment in the exemption statements cited in the example, the notation "SS" should be included at the end of the appropriate exemption statement.; Miscellaneous Exclusion Statements are found in 15 CFR part 30 subpart A § 30.2(d).
Deadline: 2025-09-15(September 15, 2025)
Market Impacts
Clarification of filing requirements for in-transit shipments and split shipments under Foreign Trade Regulations, requiring specific manifest notations and compliance with §30.28 for split shipments
Validated Company Impacts
ARROW ELECTRONICS, INC.
Arrow Electronics operates as a global distributor of electronic components and enterprise computing solutions, engaging extensively in international trade and export/import activities that require Foreign Trade Regulations compliance. The company's business model involves sourcing, engineering, and distributing technology products across borders, making it directly subject to FTR filing requirements for shipments and documentation. The Foreign Trade Regulations rule focuses on export/import documentation compliance and shipment filing requirements, which has no alignment with the company's sole disclosed risk factor of cybersecurity threats. The company's risk profile shows no mention of international trade, customs compliance, or supply chain documentation risks that would be affected by this regulation.
AVNET INC
Avnet operates as a global distributor of electronic components with significant international trade operations, requiring extensive export/import documentation and customs compliance. The company's business model directly involves handling shipments across borders, making it subject to Foreign Trade Regulations requirements for proper manifest notations and split shipment documentation. The Foreign Trade Regulations rule focuses on specific export/import documentation requirements for split shipments and exclusion statements, which does not align with any of the company's disclosed risk factors. The company's primary risks relate to customer demand changes, supply chain disruptions, competition, and cybersecurity, with only one general regulatory compliance risk that doesn't specifically address international trade documentation requirements.
Ingram Micro Holding Corp
Ingram Micro operates as a global IT solutions provider with extensive international trade operations across all major regions, directly engaging in export/import activities that require Foreign Trade Regulations compliance. The company's global supply chain and logistics operations involving split shipments and international documentation filing align directly with the rule's requirements for manifest notations and FTR compliance. The Foreign Trade Regulations rule focuses on documentation requirements for international shipments and customs compliance, which has no alignment with the company's sole identified risk of cybersecurity threats. The rule addresses operational filing procedures for trade documentation, while the company's risk profile centers on technology security and data protection concerns.
MCKESSON CORP
McKesson Corp operates as a major pharmaceutical distributor with extensive international trade operations involving import/export of medical supplies and pharmaceuticals, directly aligning with Foreign Trade Regulations requirements for documentation filing, split shipments, and exclusion statements. The company's global supply chain operations would be significantly affected by these regulatory clarifications. The company has identified compliance risks as a regulatory concern, which aligns with the Foreign Trade Regulations' filing requirements that could lead to penalties for non-compliance. However, the company's specific risk factors focus more on financial and legal contingencies rather than international trade documentation, indicating only weak alignment with this particular rule's impacts.