CBP Form 216: FTZ Activity Permit Rules for Operators

Key Points

• CBP Form 216, Application for Foreign-Trade Zone Activity Permit, is the request for CBP approval to manipulate, manufacture, exhibit or destroy merchandise already inside a foreign-trade zone; it is not the admission form.
• The zone operator or zone user files CBP Form 216 with CBP before the activity takes place, frequently as a blanket permit covering routine, repetitive operations.
• Authority runs from the Foreign-Trade Zones Act at 19 U.S.C. 81 and the CBP zone regulations, with the activity permit requirement at 19 CFR 146.52 and zone status elections at 19 CFR 146.21.
• The Form 216 collection, together with CBP Form 214, was covered by Federal Register notices published 2025-08-28 (document 2025-16498) and 2025-11-26 (document 2025-21144) extending the information collections; confirm the current status before relying on it.
• Typical failures are activity performed without an approved permit, destruction that is not witnessed or documented, and zone records that do not tie back to the admission, each of which exposes the operator's bond and the merchandise's status election.

On this page

1. What CBP Form 216 is and where the authority comes from
2. At a glance
3. Who files CBP Form 216 and when in the zone lifecycle
4. How CBP Form 216 is filed, approved, and recorded
5. What goes wrong with CBP Form 216 and what it costs
6. How CBP Form 216 relates to CBP Form 214, bonds, and entry filing
7. Frequently asked questions
8. What importers and brokers should do
9. Key references

CBP Form 216, Application for Foreign-Trade Zone Activity Permit, is the form a zone operator or zone user submits to ask CBP to approve manipulation, manufacture, exhibition or destruction of merchandise that is already inside a foreign-trade zone. It is filed before the activity begins, sits between admission and eventual entry or export in the zone lifecycle, and is distinct from CBP Form 214, Application for Foreign-Trade Zone Admission and/or Status Designation, which admits goods and elects zone status. As of September 2026, CBP Form 216 remains the standard vehicle for zone activity permits, including blanket permits for routine operations.

The links in this article go to the primary documents: the statute, the CBP zone regulations, the Federal Register notices, and the official CBP forms pages themselves. Read the source.

At a glance

• Full name: CBP Form 216, Application for Foreign-Trade Zone Activity Permit.
• Who prepares or uses it: the foreign-trade zone operator or the zone user whose merchandise will be manipulated, manufactured, exhibited or destroyed; reviewed and approved by CBP at the port.
• When in the lifecycle: after admission on CBP Form 214 and before the activity is performed, including blanket coverage for repetitive operations.
• System or channel: varies by port and by zone; confirm the accepted submission channel and format with the port director and the zone's CBP oversight contact.
• Governing authority: 19 U.S.C. 81 and the CBP zone regulations, notably 19 CFR 146.52, with status elections at 19 CFR 146.21.
• Related terms: CBP Form 214 (FTZ admission and status designation), CBP Form 301 (Customs Bond), CBP Form 7512 (in-bond transportation entry), CBP Form 7553 (notice of intent to export, destroy or return merchandise for drawback).
• Not to be confused with: CBP Form 214, or any application filed with the Commerce Foreign-Trade Zones Board.

What CBP Form 216 is and where the authority comes from

CBP Form 216 exists because a foreign-trade zone is treated, for duty purposes, as outside the customs territory, and CBP needs a permit record before merchandise under its supervision is altered, consumed, or destroyed. The Foreign-Trade Zones Act at 19 U.S.C. 81 supplies the statutory base, and the CBP implementing regulations in 19 CFR part 146 carry the operating rules, with the activity permit requirement at 19 CFR 146.52. The practical point is that admission into the zone does not carry with it a right to do anything to the goods: manipulation, manufacture, exhibition and destruction each require CBP's permission first, and CBP Form 216 is how that permission is requested and documented.

Because the form is an information collection, it is periodically renewed through Federal Register notices. Notices published on 2025-08-28 (document 2025-16498) and 2025-11-26 (document 2025-21144) covered the extension of the CBP Form 214 and CBP Form 216 collections. Confirm the current status of the collection and the current form version on the CBP forms page before building a filing template around it.

Who files CBP Form 216 and when in the zone lifecycle

CBP Form 216 is filed by the zone operator or by the zone user with the operator's involvement, and it is filed before the activity, not after. The sequence most compliance managers work with is straightforward: merchandise is admitted on CBP Form 214 with a zone status elected under 19 CFR 146.21 (privileged foreign, nonprivileged foreign, domestic or zone-restricted), the goods sit in the zone under inventory control, and when the operator wants to repack, blend, assemble, produce, display or scrap them, a CBP Form 216 permit is obtained first.

Blanket permits for routine operations

For operations that repeat continuously, such as standard repacking, labeling, kitting or line production, CBP Form 216 is commonly filed as a blanket permit rather than transaction by transaction. A blanket permit still has to describe the activity accurately. If the operator later adds a process step, a new commodity family, or a destruction method that the approved blanket permit does not describe, the permit needs to be amended or a new CBP Form 216 filed. Do not assume a legacy blanket permit covers a new production line.

Destruction cases

Destruction is the CBP Form 216 use case that draws the most scrutiny, because the merchandise disappears from inventory and the duty consequences follow the status elected at admission. Operators should agree with the port in advance on whether CBP will witness the destruction and what evidence, such as scale tickets, disposal certificates, photographs or a signed attestation, will be retained. Where the same merchandise also supports a drawback claim, note that CBP Form 7553, Notice of Intent to Export, Destroy or Return Merchandise for Purposes of Drawback, is a separate notice serving a different program and does not substitute for a zone activity permit.

How CBP Form 216 is filed, approved, and recorded

CBP Form 216 is submitted to CBP at the port with jurisdiction over the zone, and once CBP approves it the permit becomes part of the zone's audit trail. The submission channel, whether a signed document delivered to the port, an emailed package, or a port-specific electronic process, varies; confirm the accepted method with the port director rather than assuming the practice used at another zone.

Approval is only half the job. The activity has to be recorded in the operator's inventory control and recordkeeping system so that a CBP auditor can follow a single lot from admission on CBP Form 214, through the permitted activity under CBP Form 216, to the eventual outcome: transfer to the customs territory on a consumption entry, export, transfer in bond, or destruction. Quantities in and out, scrap and waste, and the resulting finished article must reconcile. Brokers most often encounter CBP Form 216 indirectly, when a type 06 zone entry presents merchandise that was manufactured in the zone or reflects quantities reduced by destruction, and the entry data has to match what the permit and the inventory records show.

What goes wrong with CBP Form 216 and what it costs

Most CBP Form 216 problems found in a zone compliance review fall into three buckets, and all three surface during an audit rather than at the moment of the activity. The first is activity performed without an approved permit, including production that quietly drifted outside the scope of an old blanket permit. The second is destruction that was neither witnessed nor documented to the standard the port expects, leaving no defensible proof that the merchandise left inventory the way the records claim. The third is records that do not tie: the permit describes one lot or quantity, the inventory system shows another, and the admission on CBP Form 214 cannot be reconciled to the outcome.

The exposure is real. Zone activity runs under the operator's bond obligations, and CBP Form 301, Customs Bond, the surety bond securing duties, taxes, fees and compliance obligations to CBP under 19 CFR part 113, is the instrument CBP looks to when merchandise cannot be accounted for. Status elections made at admission can also be put at risk: if the record chain breaks, the favorable treatment the operator relied on may not hold when duties are calculated at entry. Where a review uncovers past activity that lacked a permit, the operator should consider whether a prior disclosure is the right route.

How CBP Form 216 relates to CBP Form 214, bonds, and entry filing

CBP Form 216 is the middle link in a chain that starts with CBP Form 214 and ends with an entry, an export, or a documented destruction. CBP Form 214, Application for Foreign-Trade Zone Admission and/or Status Designation, admits the merchandise and fixes the zone status; see our reference entry on CBP Form 214. CBP Form 7512, Transportation Entry and Manifest of Goods Subject to CBP Inspection and Permit, the in-bond application for moving unentered goods under bond, may carry merchandise to or from the zone; see CBP Form 7512. Continuous bond sufficiency is a standing concern for operators, covered in CBP Form 301.

Several other CBP forms touch zone operators indirectly. CBP Form 5106, Create/Update Importer Identity Form, registers or updates an importer of record or ultimate consignee identity in ACE under 19 CFR 24.5, and the zone user withdrawing goods for consumption must be correctly identified there. If CBP later disagrees with the duty treatment of merchandise withdrawn from the zone, the contest route is CBP Form 19, Protest, the form used to contest a CBP decision under 19 U.S.C. 1514 such as liquidation, classification, value or rate. None of these replace the activity permit itself.

Frequently asked questions

Is CBP Form 216 the same as CBP Form 214?

No. CBP Form 216 permits activity on merchandise that is already in the zone, while CBP Form 214 admits merchandise into the zone and elects its zone status under 19 CFR 146.21. A zone operator needs both forms in the file for a lot that is admitted and then manipulated, manufactured or destroyed.

Does CBP Form 216 go to the Foreign-Trade Zones Board?

No. CBP Form 216 is a CBP permit application handled at the port under 19 CFR 146.52; filings made with the Commerce Foreign-Trade Zones Board are a separate process and do not substitute for a CBP activity permit.

Can one CBP Form 216 cover repeating operations?

Yes. CBP Form 216 is often filed as a blanket permit for routine, repetitive activity, but the permit must accurately describe the activity performed, and a new or amended CBP Form 216 is needed when the process, the merchandise, or the destruction method changes.

How does CBP Form 216 show up in a broker's work?

Brokers typically meet CBP Form 216 when a type 06 zone entry reflects goods that were manufactured or destroyed inside the zone, because the entered article, quantity and value have to be consistent with the permitted activity and the operator's inventory records.

What importers and brokers should do

• Inventory every open blanket CBP Form 216 against the operations actually running today, and file new or amended permits where the described activity has drifted.
• Agree in writing with the port on destruction evidence, including whether CBP will witness, and retain that evidence with the CBP Form 216 and the related CBP Form 214 in a single lot file.
• Run a reconciliation test on a sample lot from admission through activity to entry or export, and fix any break before CBP's auditors find it.
• Check the current CBP Form 216 version and the status of the information collection on the CBP forms page and in the Federal Register before revising internal templates.

Key references

• 19 U.S.C. 81: the Foreign-Trade Zones Act provision underpinning zone operations.
• 19 CFR 146.52: the CBP regulation requiring an approved permit for zone activity.
• 19 CFR 146.21: zone status designations elected at admission.
• Federal Register notice published 2025-08-28 (2025-16498): extension of the CBP Form 214 and CBP Form 216 information collections.
• Federal Register notice published 2025-11-26 (2025-21144): further notice on the CBP Form 214 and CBP Form 216 collections.
• CBP forms library: current official version of CBP Form 216 and related CBP forms.
• Harmonized Tariff Schedule of the United States: classification reference for merchandise entered from a zone.