FTZ and IMCR - Using IMCR for Chapter 99 additions and replacements
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.The complexities of FTZ on hand inventory require more flexibility when managing tariff applications. As IMCR functionality is continually enhanced to serve zone needs, this document serves as guidance on how FTZ’s can utilize Item Master Custom Rules (IMCR) for filing changes. For FTZ’s this is especially beneficial if past applications of IMCR either missed adding specific chapter 99’s, applied an incorrect chapter 99, or, simply due to the length of time a layer has been in the zone, it now requires different additional tariffs than in the past.
Please keep in mind:
- IMCR currently can not be used to remove an HTS entirely. It can add an HTS and it can replace an HTS, but the complete removal of an HTS is not yet possible.
- Inventory layers in an FTZ always display the most recent Chapter 99 configuration. For instance, if a layer of 100 units is received and initially requires only one Chapter 99, but later additional Chapter 99s are needed for subsequent 7501 entries, the entire layer will be updated to include these new Chapter 99s. Your shipment PDFs will preserve the original filing details and serve as your official record, provided you do not re-generate the 7501 after final submission. As a best practice, only use the 'Generate' link on a 7501 when you intend to file the updated entry with CBP. Additionally, our system maintains a database view of previous entry data and versions of all generated PDFs for reference.
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.Adding a missing HTS in IMCR
If an existing inventory layer has already had a chapter 99 applied, but now needs additional chapter 99 HTS, IMCR can be utilized to ‘slot in’ missing chapter 99 HTS numbers.For example, an inventory layer looks like this:
- 99038803 – HTS Sequence 1 (301 Tariff Type)
- 7408190030 – HTS Sequence 2 (Commodity HTS)
If the entry requires an IEEPA-Fentanyl, IEEPA-Reciprocal and 232 in addition to the 301 already on the layer, these additional chapter 99 numbers can be added in utilizing IMCR.
- The StartEffectiveDate should be backdated to when the rule is first active. This is important because the system uses the date to determine whether to apply a rule or not during Entry Generation (inpurple).
- Ensure the main IMCR ‘Match HTS Index’ is your current inventory layer’s HTS Sequence 1 (inorange).
- Ensure the sequence breakout ‘Match Record’ is checked and ‘Match HTS Number’ fields are filled in with the HTS of the existing inventory layer in the order you want (inred).
- The HTS that need to be added should not have the ‘Match Record’ field checked and the ‘Match HTS Number’ fields should be blank (ingreen).
- See below a sample of how the IMCR would look:

Replacing an incorrect HTS in IMCR
If an existing inventory layer has an incorrect chapter 99 applied, and needs a different Chapter 99 HTS, IMCR can be utilized to ‘replace’ a chapter 99 HTS numbers.For example, an inventory layer looks like this:
- 99038815 – HTS Sequence 1 (301 Tariff Type)
- 7408190030 – HTS Sequence 2 (Commodity HTS)
If the entry requires a different 301 chapter 99, replace with the correct 301 chapter 99 number utilizing IMCR.
- The StartEffectiveDate should be backdated to when the rule is first active. This is important because the system uses the date to determine whether to apply a rule or not during Entry Generation (inpurple).
- Ensure the main IMCR ‘Match HTS Index’ is your current inventory layer’s HTS Sequence 1 (inorange).
- Ensure the sequence breakout ‘Match Record’ is checked and ‘Match HTS Number’ fields are filled in with the HTS of the existing inventory layer in the order you want (inred).
- The HTS(s) that need to be ‘replaced’ should have the corrected HTS number in the ‘Update to HTS Index’ fields (ingreen).
- See below a sample of how the IMCR would look:

Switching HTS to a different sequence order in IMCR
If an existing inventory layer has the chapter 99 numbers in an incorrect sequence order, IMCR can be utilized to switch the HTS into a different order.For example, an inventory layer looks like this:
- 9903.01.26 – HTS Sequence 1 (IEEPA-Reciprocal)
- 9903.01.10 – HTS Sequence 2 (IEEPA-Fentanyl)
- 6201.20.1110 – HTS Sequence 3
If it is determined that the IEEPA-Fentanyl should come before the IEEPA-Reciprocal, a new IMCR can be set to switch the chapter 99 numbers to a different sequence.
- The StartEffectiveDate should be backdated to when the rule is first active. This is important because the system uses the date to determine whether to apply a rule or not during Entry Generation (inpurple).
- Ensure the main IMCR ‘Match HTS Index’ is your current inventory layer’s HTS Sequence 1 (inorange).
- Ensure the sequence breakout ‘Match Record’ is checked and ‘Match HTS Number’ fields are filled in with the HTS of the existing inventory layer (inred).
- The HTS(s) that now need to be ‘reordered’ should have the HTS number you want the layer to become in the ‘Update to HTS Index’ fields, in the sequence you now want (ingreen).
- See below a sample of how the IMCR would look:

Updating a full layer to a partial value content layer in IMCR
If an existing inventory layer has a full value and it is determined that part of the product can be portioned out to only pay duty on a part of the value, IMCR can be utilized to ‘update’ a layer to indicate a ‘split’.For example, an inventory layer looks like this:
- 9903.01.33 – HTS Sequence 1
- 9903.81.90 – HTS Sequence 2
- 7301.20.1000 – HTS Sequence 3 (Value 10)
If it is determined that the 232 portion is $2 dollars of the $10 total value, a new IMCR can be set to break out this value and create the split.
- The StartEffectiveDate should be backdated to when the rule is first active. This is important because the system uses the date to determine whether to apply a rule or not during Entry Generation (inpurple).
- Ensure the main IMCR ‘Match HTS Index’ is your current inventory layer’s HTS Sequence 1 (inorange).
- Ensure the sequence breakout ‘Match Record’ is checked and ‘Match HTS Number’ fields are filled in with the HTS of the existing inventory layer (inred).
- The HTS(s) that now need to be ‘replaced/reordered’ should have the HTS number you want the layer to become in the ‘Update to HTS Index’ fields, in the sequence you now want (ingreen). Remember, to indicate a partial value, the tariff type that is being split out needs to come after the commodity HTS.
Ensure you put the value breakout for the tariff in the value fields (in
blue
). Please see the guide on Split Tariff Line Reporting/Swapping for specifics on requirements.- See below a sample of how the IMCR would look:
