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Last updated: General CBP FTZ operator bond information — confirm current requirements with the licensing authority.
Activity Code 4 • Continuous • CBP Form 301

Foreign Trade Zone (FTZ) Operator Bond

A Foreign Trade Zone operator bond is CBP's Activity Code 4 continuous bond, minimum $50,000, and it is the switch that turns your zone on. Under 19 CFR 146.6(d), once CBP approves your activation application, "a Foreign Trade Zone Operator's Bond shall be executed on Customs Form 301" — and 146.6(e) says the site is not considered activated until the port director accepts that executed bond.

Its conditions live in 19 CFR 113.73: you guarantee the receipt, admission, status, handling, transfer, removal, and recordkeeping of every item in the zone. The $50,000 is a floor set by CBP's Monetary Guidelines — the port director sets the real penal sum from the value at risk.

$50K
Minimum penal sum
Code 4
CBP activity code
146.6
Activation rule

What You Are Actually Promising CBP

An FTZ operator holds duty-suspended goods on U.S. soil that CBP is not physically guarding. The bond is what makes that trust workable — 19 CFR 113.73 spells out five distinct conditions the operator and surety guarantee. This is not boilerplate; each one is a separate way the bond can be called.

Lawful handling of everything in the zone

§ 113.73(a)

The operator agrees to comply with the law and CBP regulations governing the receipt, admission, status, handling, transfer, and removal of merchandise, and to maintain the required inventory-control and recordkeeping system. This is the core promise — CBP is not physically guarding your zone, so the bond backs your paperwork.

Duties on anything that goes missing

§ 113.73(b)

If merchandise that should be in the zone cannot be accounted for, the operator and surety agree to pay any duties, taxes, and charges found due on it. A shrinkage or inventory-reconciliation gap becomes a bonded liability, not just a bookkeeping note.

Importer Security Filing compliance

§ 113.73(c)

The bond folds in the ISF (10+2) condition — the operator agrees to comply with all Importer Security Filing requirements in 19 CFR Part 149, with $5,000 liquidated damages per violation. An FTZ operator bond is one of the qualifying bonds that satisfies the ISF filing requirement under 19 CFR 149.5.

Exoneration and reimbursement of CBP

§ 113.73(d)

The operator agrees to hold the United States and its officers harmless from any risk, loss, or expense arising from zone operations, and to reimburse CBP for the compensation of officers when the regulations require it.

Timely payment of the annual FTZ fee

§ 113.73(e)

The operator agrees to pay the annual foreign-trade-zone fee on time. The condition carries escalating penalty percentages for amounts left in arrears — a reminder that this is a continuous, year-over-year obligation, not a one-and-done filing.

Where the Bond Sits in the Activation Sequence

Foreign trade zones run under 19 CFR Part 146. Getting a grant of authority from the FTZ Board is only the first step — a zone produces no duty benefit until CBP activates the site, and the operator bond is the last thing that has to fall into place. Here is the order it actually happens in.

  1. 1

    Grant of authority

    The FTZ Board designates the zone or subzone. At this point the site exists on paper but cannot receive merchandise in FTZ status.

  2. 2

    Application to activate (19 CFR 146.6)

    The operator files the activation application with the port director, including the procedures and inventory-control system it will use to account for goods.

  3. 3

    Bond executed on Form 301 (146.6(d))

    On approval of the application, the Activity 4 operator bond "shall be executed on Customs Form 301" with the 113.73 conditions. This is your step — and the one this page exists to handle.

  4. 4

    Activation (146.6(e))

    Only "upon the port director's approval of the application and acceptance of the executed bond" is the site considered activated. Now merchandise can be admitted in zone status and the duty benefits begin.

The practical takeaway: an approved activation application is not the finish line. If the bond is not executed and accepted, the zone stays dark and every day of delay is a day you are paying duties you could have deferred. Line up the surety the moment approval is in sight.

$50,000 Is the Floor — Here Is How CBP Sizes It Up

CBP's Monetary Guidelines for Setting Bond Amounts (Directive 3510-004) set $50,000 as the Activity 4 minimum, but the port director scales the penal sum to the revenue at risk: the value of merchandise you hold and the duties that would be owed if it could not be accounted for. Premium is a fraction of the penal sum, so a right-sized bond keeps your cost honest. These are typical bands, not statutory figures.

Small / startup zone
$50,000
Under $500K of merchandise on hand

The CBP Monetary Guidelines floor. Most new general-purpose zone operators start here.

Active distribution zone
$50,000 – $250,000
$500K – $5M peak inventory

The port director scales the penal sum to the revenue at risk once real volume moves through.

High-volume manufacturing subzone
$250,000+
Over $5M peak inventory

Large manufacturing subzones (auto, pharma, oil) are commonly bonded well into the six figures.

Penal-sum ranges are underwriting estimates from Treasury-listed sureties; only the $50,000 minimum is a fixed CBP guideline (Directive 3510-004). Premium depends on the final penal sum, the operator's financials, and the merchandise profile. Get an exact figure from the quote form.

The Regulation, Word for Word

Official CBP Requirements

"On approval of the application, a Foreign Trade Zone Operator's Bond shall be executed on Customs Form 301, containing the bond conditions set forth in § 113.73 of this chapter."
U.S. Customs and Border Protection • 19 CFR § 146.6(d) — Bond Executed on Approval

Official CBP Requirements

"The zone or zone site will be considered activated when the port director... has approved the application, and has accepted the executed Foreign Trade Zone Operator's Bond."
Electronic Code of Federal Regulations • 19 CFR § 146.6(e) — Zone Activation

Official CBP Requirements

"The principal agrees to comply with the law and Customs Regulations related to the receipt, admission, status, handling, transfer, and removal of merchandise... and to maintain the inventory control and recordkeeping system."
Electronic Code of Federal Regulations • 19 CFR § 113.73(a) — FTZ Operator Bond Conditions

Official CBP Requirements

"If merchandise is found to be missing from the zone... the obligors (principal and surety) agree to pay any duties, taxes, and charges found to be due on that merchandise."
Electronic Code of Federal Regulations • 19 CFR § 113.73(b) — Liability for Missing Merchandise

External .gov links open in a new tab and are marked rel="nofollow noopener noreferrer". Quotations are condensed from the eCFR conditions; read the full text at the linked sections.

Approval in sight? Get the Form 301 bond ready.

Tell us your zone type and inventory profile — we'll size the Activity 4 penal sum and have the bond ready to execute the day CBP approves your activation.

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FTZ Operator Bond Questions

Why does CBP make me post this bond before it will activate my zone?
Because activation and the bond are legally linked. Under 19 CFR 146.6(d), once the port director approves your activation application, "a Foreign Trade Zone Operator's Bond shall be executed on Customs Form 301." Section 146.6(e) then states the zone or zone site is not considered activated until "the port director's approval of the application and acceptance of the executed bond." In other words, an approved application alone does not let you operate — CBP treats the accepted Activity 4 bond as the switch that turns the zone on. Get the bond issued as soon as approval lands so your activation date does not slip.
Is $50,000 the amount I will actually be bonded for, or can CBP require more?
The $50,000 is a minimum, not a fixed number. CBP's Monetary Guidelines for Setting Bond Amounts (Directive 3510-004) set $50,000 as the floor for the Activity Code 4 FTZ operator bond, but the port director sets the actual penal sum based on the revenue at risk — chiefly the value of merchandise and the duties, taxes, and charges that could be owed if inventory could not be accounted for. A small startup zone may sit at the $50,000 floor; a high-volume manufacturing subzone is routinely bonded into the six figures. The bond is continuous, so the penal sum can be adjusted as your zone's activity grows.
Do general-purpose zones and subzones both need the operator bond?
Yes. The Activity Code 4 bond is tied to the act of operating an activated zone site, not to the label on it. Whether you run a general-purpose zone, a subzone, or a usage-driven site, the operator that is responsible to CBP for the merchandise must file the 19 CFR 113.73 bond on Form 301 as part of activation under 146.6. If a single grantee has multiple activated sites under different operators, each responsible operator carries its own bond.
If I already carry the FTZ operator bond, do I need a separate ISF bond for ocean cargo?
No. The FTZ operator bond already contains the Importer Security Filing condition in 19 CFR 113.73(c), and 19 CFR 149.5 explicitly lists "a foreign trade zone operator bond containing all the necessary provisions of § 113.73" among the bonds that qualify an ISF Importer to file. Buying a standalone ISF bond on top of an active Activity 4 bond pays twice for the same $5,000-per-violation coverage. If you are weighing the standalone product, see our ISF bond breakdown before adding it.
What happens to the bond if merchandise goes missing from the zone?
That is exactly the exposure the bond is built for. Under 19 CFR 113.73(b), if merchandise that should be in the zone is found missing, the operator and surety are jointly liable for any duties, taxes, and charges found due on it. Practically, this means a failed inventory reconciliation or an unexplained shrinkage in your recordkeeping system can convert into a demand against the bond — which is why CBP weights the penal sum toward the value of goods you hold, and why your inventory-control system under 113.73(a) is doing real work, not just satisfying an audit.
Is the FTZ operator bond a one-time filing or does it renew every year?
It is a continuous bond. 19 CFR 113.73 requires the FTZ operator bond to be written as a continuous bond, so it stays in force year over year rather than covering a single transaction the way a single-entry import bond does. The 113.73(e) condition to pay the annual FTZ fee on time — with penalties for arrears — reinforces that this is an ongoing obligation for as long as your zone is activated. You renew the surety premium annually; the bond itself does not lapse and re-file each year.
Eric Drummond, Licensed Surety Producer
Reviewed by
Eric Drummond, Licensed Surety Producer

All content is researched from official state and federal sources (.gov). BuySuretyBonds.com works with Treasury-listed surety carriers.

Don't Let the Bond Be What Stalls Your Zone

Your zone isn't activated until CBP accepts the executed Form 301 bond. Get it sized and issued now so activation is a formality, not a bottleneck.

Prefer to talk it through? Call 1-844-810-BOND (2663)