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Bonded Warehouses

Types of bonded warehouses, permitted operations, time limits, and withdrawal procedures.

19 CFR 1919 CFR 144

Structured from CBP-designated exam references; confirm the editions approved for your exam sitting.

The textbook layer behind Study Map

From learning route to full explanation

This guide covers warehouse-entry eligibility, the importation-date storage clock, custody and proprietor responsibility, the persons legally entitled to withdraw, and the separate consumption, transportation, and export routes. Filing is kept distinct from CBP's permit and physical delivery.

Study Map tells you what to learn and in what order; this page explains the rules, decision method, and boundaries. Reading completion is not proof of mastery.

Textbook chapter 1

Make a warehouse entry and start the correct clock

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Answer first

Determine whether merchandise is eligible for warehouse entry, identify the entry filing route, and calculate the warehousing period from the legally controlling date. Dutiable merchandise may generally be entered for warehousing, but perishable merchandise and explosive substances other than firecrackers are excluded; dangerous or highly flammable merchandise requires the warehouse insurer's written consent. Entry documentation required by §142.3 is filed at entry. A timely Form 7501 or electronic equivalent can serve as both entry and entry summary. The warehousing period runs from the date of importation, not the date of warehouse entry, and is generally capped at five years, subject under current §144.5 to a discretionary longer period on proper request and good cause. Current law was reviewed on 2026-08-18 against the eCFR text current through 2026-08-14. For the October 2026 CBLE, answer from the exam-designated 2025 CFR edition when its wording or numbering differs from live law.

Rule breakdown

Controlling rule for Make a warehouse entry and start the correct clock

19 CFR 144.1; 144.5; 144.11 ↗

The result must be derived from the cited legal elements rather than from a label, commercial expectation, or memorized shortcut. Dutiable merchandise may generally be entered for warehousing, but perishable merchandise and explosive substances other than firecrackers are excluded; dangerous or highly flammable merchandise requires the warehouse insurer's written consent. Entry documentation required by §142.3 is filed at entry. A timely Form 7501 or electronic equivalent can serve as both entry and entry summary. The warehousing period runs from the date of importation, not the date of warehouse entry, and is generally capped at five years, subject under current §144.5 to a discretionary longer period on proper request and good cause. Current law was reviewed on 2026-08-18 against the eCFR text current through 2026-08-14. For the October 2026 CBLE, answer from the exam-designated 2025 CFR edition when its wording or numbering differs from live law. Apply every stated condition to the documented facts and stop if an essential condition cannot be proved.

Evidence route for Make a warehouse entry and start the correct clock

19 CFR 144.1; 144.5; 144.11; 19 CFR 19.6(a); 19 CFR Part 144 (2025 edition); 19 U.S.C. 1557(a) ↗

Use the official source in the order required by the issue and record both the rule and the fact that satisfies it. The assigned lookup is: Find the excluded merchandise classes in §144.1, then locate the event that starts the five-year warehousing period in §144.5. Follow this source route: Read §144.1(a), skip to §144.5, and contrast 'date of importation' with the filing date discussed in §144.11.. A technically accepted filing or a completed reading is not itself proof that the legal outcome is correct.

Decision path

  1. 1

    Set the gate for Make a warehouse entry and start the correct clock

    Determine whether merchandise is eligible for warehouse entry, identify the entry filing route, and calculate the warehousing period from the legally controlling date. Identify the legally significant party, merchandise, event, date, value, status, and document before selecting a rule or performing a calculation.

  2. 2

    Verify 19 CFR 144.1; 144.5; 144.11

    Open 19 CFR 144.1; 144.5; 144.11, complete the chapter lookup task, and preserve the exact subsection, table, form, or agency guide used. Follow Read §144.1(a), skip to §144.5, and contrast 'date of importation' with the filing date discussed in §144.11. rather than jumping directly to a remembered result.

  3. 3

    Test the boundary of Make a warehouse entry and start the correct clock

    Apply each controlling element to the documented facts, calculate only after eligibility is established, and compare the result with the worked example conclusion: The importation date controls, so the ordinary five-year limit is measured from May 1, 2026. Record any unresolved fact instead of converting uncertainty into a pass or mastery claim.

Worked example

Scenario: Dutiable machinery is imported on May 1, 2026, and entered for warehouse on June 15, 2026. No discretionary extension is granted. What date controls the ordinary five-year limit?

  1. 1.Confirm that the machinery is dutiable and no stated §144.1 exclusion applies.
  2. 2.Separate the importation date from the later warehouse-entry date.
  3. 3.Apply §144.5 from May 1, 2026, rather than June 15, 2026.
  4. 4.Set the ordinary outer limit at May 1, 2031, absent an approved longer period.
  5. 5.Boundary check: change one decisive fact identified by “Find the excluded merchandise classes in §144.1, then locate the event that starts the five-year warehousing period in §144.5.” and explain whether the result changes under 19 CFR 144.1; 144.5; 144.11; 19 CFR 19.6(a); 19 CFR Part 144 (2025 edition); 19 U.S.C. 1557(a).

Conclusion: The importation date controls, so the ordinary five-year limit is measured from May 1, 2026.

Common traps and corrections

× Starting the five-year clock on the warehouse-entry or physical-deposit date.

✓ The shortcut “Starting the five-year clock on the warehouse-entry or physical-deposit date.” skips a controlling distinction in Make a warehouse entry and start the correct clock. Return to 19 CFR 144.1; 144.5; 144.11, follow Read §144.1(a), skip to §144.5, and contrast 'date of importation' with the filing date discussed in §144.11., and test the decisive fact against this boundary: Dutiable merchandise may generally be entered for warehousing, but perishable merchandise and explosive substances other than firecrackers are excluded; dangerous or highly flammable merchandise requires the warehouse insurer's written consent. Entry documentation required by §142.3 is filed at entry. A timely Form 7501 or electronic equivalent can serve as both entry and entry summary. The warehousing period runs from the date of importation, not the date of warehouse entry, and is generally capped at five years, subject under current §144.5 to a discretionary longer period on proper request and good cause. Current law was reviewed on 2026-08-18 against the eCFR text current through 2026-08-14. For the October 2026 CBLE, answer from the exam-designated 2025 CFR edition when its wording or numbering differs from live law. Do not infer eligibility, release, or mastery from the shortcut.

× Assuming every dutiable article is eligible without checking perishability, explosives, or insurer consent.

✓ The shortcut “Assuming every dutiable article is eligible without checking perishability, explosives, or insurer consent.” skips a controlling distinction in Make a warehouse entry and start the correct clock. Return to 19 CFR 144.1; 144.5; 144.11, follow Read §144.1(a), skip to §144.5, and contrast 'date of importation' with the filing date discussed in §144.11., and test the decisive fact against this boundary: Dutiable merchandise may generally be entered for warehousing, but perishable merchandise and explosive substances other than firecrackers are excluded; dangerous or highly flammable merchandise requires the warehouse insurer's written consent. Entry documentation required by §142.3 is filed at entry. A timely Form 7501 or electronic equivalent can serve as both entry and entry summary. The warehousing period runs from the date of importation, not the date of warehouse entry, and is generally capped at five years, subject under current §144.5 to a discretionary longer period on proper request and good cause. Current law was reviewed on 2026-08-18 against the eCFR text current through 2026-08-14. For the October 2026 CBLE, answer from the exam-designated 2025 CFR edition when its wording or numbering differs from live law. Do not infer eligibility, release, or mastery from the shortcut.

× Treating Form 3461 and Form 7501 as interchangeable without checking whether the entry summary was filed at entry.

✓ The shortcut “Treating Form 3461 and Form 7501 as interchangeable without checking whether the entry summary was filed at entry.” skips a controlling distinction in Make a warehouse entry and start the correct clock. Return to 19 CFR 144.1; 144.5; 144.11, follow Read §144.1(a), skip to §144.5, and contrast 'date of importation' with the filing date discussed in §144.11., and test the decisive fact against this boundary: Dutiable merchandise may generally be entered for warehousing, but perishable merchandise and explosive substances other than firecrackers are excluded; dangerous or highly flammable merchandise requires the warehouse insurer's written consent. Entry documentation required by §142.3 is filed at entry. A timely Form 7501 or electronic equivalent can serve as both entry and entry summary. The warehousing period runs from the date of importation, not the date of warehouse entry, and is generally capped at five years, subject under current §144.5 to a discretionary longer period on proper request and good cause. Current law was reviewed on 2026-08-18 against the eCFR text current through 2026-08-14. For the October 2026 CBLE, answer from the exam-designated 2025 CFR edition when its wording or numbering differs from live law. Do not infer eligibility, release, or mastery from the shortcut.

× Assuming an extension is automatic rather than discretionary on a proper request and good cause.

✓ The shortcut “Assuming an extension is automatic rather than discretionary on a proper request and good cause.” skips a controlling distinction in Make a warehouse entry and start the correct clock. Return to 19 CFR 144.1; 144.5; 144.11, follow Read §144.1(a), skip to §144.5, and contrast 'date of importation' with the filing date discussed in §144.11., and test the decisive fact against this boundary: Dutiable merchandise may generally be entered for warehousing, but perishable merchandise and explosive substances other than firecrackers are excluded; dangerous or highly flammable merchandise requires the warehouse insurer's written consent. Entry documentation required by §142.3 is filed at entry. A timely Form 7501 or electronic equivalent can serve as both entry and entry summary. The warehousing period runs from the date of importation, not the date of warehouse entry, and is generally capped at five years, subject under current §144.5 to a discretionary longer period on proper request and good cause. Current law was reviewed on 2026-08-18 against the eCFR text current through 2026-08-14. For the October 2026 CBLE, answer from the exam-designated 2025 CFR edition when its wording or numbering differs from live law. Do not infer eligibility, release, or mastery from the shortcut.

Frequently asked questions

Which fact controls first for Make a warehouse entry and start the correct clock?

Begin with the chapter objective and the legally controlling facts, not with the desired commercial result. Determine whether merchandise is eligible for warehouse entry, identify the entry filing route, and calculate the warehousing period from the legally controlling date. Then use 19 CFR 144.1; 144.5; 144.11 and the remaining cited sources to test every required element before calculating or filing.

Where should I verify Make a warehouse entry and start the correct clock for the exam and live work?

For the October 28, 2026 CBLE, use the designated exam source card and pinpoint 19 CFR 144.1; 144.5; 144.11. For live work, separately verify the dated current source cards for this chapter as of the transaction date; a current statute, eCFR, HTSUS, recordation, or agency guide does not silently amend the exam edition.

Official sources and editions

Textbook chapter 2

Choose who may withdraw and which route applies

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Answer first

Identify the person with the right to withdraw and select the consumption, transportation, or exportation procedure. Only the person primarily liable for duties may withdraw bonded merchandise: the importer of record on the warehouse entry, an actual owner with the required declaration and superseding bond, or a transferee that received withdrawal rights under Part 144 Subpart C. Consumption withdrawal uses Form 7501 or its electronic equivalent; direct or indirect exportation generally uses a Part 18 in-bond application; transportation to another port is allowed only when final consumption or export withdrawal can be completed there before the warehousing period expires. Merchandise is not released merely because a withdrawal was filed: the approved permit evidences CBP authorization. Current law was reviewed on 2026-08-18 against the eCFR text current through 2026-08-14. For the October 2026 CBLE, answer from the exam-designated 2025 CFR edition when its wording or numbering differs from live law.

Rule breakdown

Controlling rule for Choose who may withdraw and which route applies

19 CFR 144.31-144.39 ↗

The result must be derived from the cited legal elements rather than from a label, commercial expectation, or memorized shortcut. Only the person primarily liable for duties may withdraw bonded merchandise: the importer of record on the warehouse entry, an actual owner with the required declaration and superseding bond, or a transferee that received withdrawal rights under Part 144 Subpart C. Consumption withdrawal uses Form 7501 or its electronic equivalent; direct or indirect exportation generally uses a Part 18 in-bond application; transportation to another port is allowed only when final consumption or export withdrawal can be completed there before the warehousing period expires. Merchandise is not released merely because a withdrawal was filed: the approved permit evidences CBP authorization. Current law was reviewed on 2026-08-18 against the eCFR text current through 2026-08-14. For the October 2026 CBLE, answer from the exam-designated 2025 CFR edition when its wording or numbering differs from live law. Apply every stated condition to the documented facts and stop if an essential condition cannot be proved.

Use the official source in the order required by the issue and record both the rule and the fact that satisfies it. The assigned lookup is: Find the three persons who may have the right to withdraw, then map consumption, exportation, and transportation to §§144.36-144.38. Follow this source route: Begin at §144.31, then read the headings and opening paragraphs of §§144.36, 144.37, 144.38, and finish at the permit rule in §144.39.. A technically accepted filing or a completed reading is not itself proof that the legal outcome is correct.

Decision path

  1. 1

    Set the gate for Choose who may withdraw and which route applies

    Identify the person with the right to withdraw and select the consumption, transportation, or exportation procedure. Identify the legally significant party, merchandise, event, date, value, status, and document before selecting a rule or performing a calculation.

  2. 2

    Verify 19 CFR 144.31-144.39

    Open 19 CFR 144.31-144.39, complete the chapter lookup task, and preserve the exact subsection, table, form, or agency guide used. Follow Begin at §144.31, then read the headings and opening paragraphs of §§144.36, 144.37, 144.38, and finish at the permit rule in §144.39. rather than jumping directly to a remembered result.

  3. 3

    Test the boundary of Choose who may withdraw and which route applies

    Apply each controlling element to the documented facts, calculate only after eligibility is established, and compare the result with the worked example conclusion: No. Commercial ownership alone does not place T within a §144.31 category; withdrawal rights must be established through one of the listed regulatory routes. Record any unresolved fact instead of converting uncertainty into a pass or mastery claim.

Worked example

Scenario: Company T bought bonded merchandise from the warehouse-entry importer, but no transfer of withdrawal rights was completed under Part 144 Subpart C. T files a consumption withdrawal on Form 7501. May T withdraw solely because it owns the goods commercially?

  1. 1.Start with §144.31 rather than commercial title alone.
  2. 2.Identify the warehouse-entry importer as the person primarily liable unless another listed route applies.
  3. 3.Check for an actual-owner declaration and superseding bond or a valid transfer of withdrawal rights.
  4. 4.Reject T's withdrawal because the facts establish neither alternative.
  5. 5.Boundary check: change one decisive fact identified by “Find the three persons who may have the right to withdraw, then map consumption, exportation, and transportation to §§144.36-144.38.” and explain whether the result changes under 19 CFR 144.31-144.39; 19 CFR 19.6(b)-(d); 19 CFR Part 144 (2025 edition); 19 CFR Part 19 (2025 edition).

Conclusion: No. Commercial ownership alone does not place T within a §144.31 category; withdrawal rights must be established through one of the listed regulatory routes.

Common traps and corrections

× Equating commercial ownership with the regulatory right to withdraw.

✓ The shortcut “Equating commercial ownership with the regulatory right to withdraw.” skips a controlling distinction in Choose who may withdraw and which route applies. Return to 19 CFR 144.31-144.39, follow Begin at §144.31, then read the headings and opening paragraphs of §§144.36, 144.37, 144.38, and finish at the permit rule in §144.39., and test the decisive fact against this boundary: Only the person primarily liable for duties may withdraw bonded merchandise: the importer of record on the warehouse entry, an actual owner with the required declaration and superseding bond, or a transferee that received withdrawal rights under Part 144 Subpart C. Consumption withdrawal uses Form 7501 or its electronic equivalent; direct or indirect exportation generally uses a Part 18 in-bond application; transportation to another port is allowed only when final consumption or export withdrawal can be completed there before the warehousing period expires. Merchandise is not released merely because a withdrawal was filed: the approved permit evidences CBP authorization. Current law was reviewed on 2026-08-18 against the eCFR text current through 2026-08-14. For the October 2026 CBLE, answer from the exam-designated 2025 CFR edition when its wording or numbering differs from live law. Do not infer eligibility, release, or mastery from the shortcut.

× Using a consumption withdrawal form for an indirect export movement without checking Part 18.

✓ The shortcut “Using a consumption withdrawal form for an indirect export movement without checking Part 18.” skips a controlling distinction in Choose who may withdraw and which route applies. Return to 19 CFR 144.31-144.39, follow Begin at §144.31, then read the headings and opening paragraphs of §§144.36, 144.37, 144.38, and finish at the permit rule in §144.39., and test the decisive fact against this boundary: Only the person primarily liable for duties may withdraw bonded merchandise: the importer of record on the warehouse entry, an actual owner with the required declaration and superseding bond, or a transferee that received withdrawal rights under Part 144 Subpart C. Consumption withdrawal uses Form 7501 or its electronic equivalent; direct or indirect exportation generally uses a Part 18 in-bond application; transportation to another port is allowed only when final consumption or export withdrawal can be completed there before the warehousing period expires. Merchandise is not released merely because a withdrawal was filed: the approved permit evidences CBP authorization. Current law was reviewed on 2026-08-18 against the eCFR text current through 2026-08-14. For the October 2026 CBLE, answer from the exam-designated 2025 CFR edition when its wording or numbering differs from live law. Do not infer eligibility, release, or mastery from the shortcut.

× Moving merchandise to another port when final withdrawal cannot occur before the warehouse period expires.

✓ The shortcut “Moving merchandise to another port when final withdrawal cannot occur before the warehouse period expires.” skips a controlling distinction in Choose who may withdraw and which route applies. Return to 19 CFR 144.31-144.39, follow Begin at §144.31, then read the headings and opening paragraphs of §§144.36, 144.37, 144.38, and finish at the permit rule in §144.39., and test the decisive fact against this boundary: Only the person primarily liable for duties may withdraw bonded merchandise: the importer of record on the warehouse entry, an actual owner with the required declaration and superseding bond, or a transferee that received withdrawal rights under Part 144 Subpart C. Consumption withdrawal uses Form 7501 or its electronic equivalent; direct or indirect exportation generally uses a Part 18 in-bond application; transportation to another port is allowed only when final consumption or export withdrawal can be completed there before the warehousing period expires. Merchandise is not released merely because a withdrawal was filed: the approved permit evidences CBP authorization. Current law was reviewed on 2026-08-18 against the eCFR text current through 2026-08-14. For the October 2026 CBLE, answer from the exam-designated 2025 CFR edition when its wording or numbering differs from live law. Do not infer eligibility, release, or mastery from the shortcut.

× Treating a filed withdrawal as CBP authorization without the approved permit.

✓ The shortcut “Treating a filed withdrawal as CBP authorization without the approved permit.” skips a controlling distinction in Choose who may withdraw and which route applies. Return to 19 CFR 144.31-144.39, follow Begin at §144.31, then read the headings and opening paragraphs of §§144.36, 144.37, 144.38, and finish at the permit rule in §144.39., and test the decisive fact against this boundary: Only the person primarily liable for duties may withdraw bonded merchandise: the importer of record on the warehouse entry, an actual owner with the required declaration and superseding bond, or a transferee that received withdrawal rights under Part 144 Subpart C. Consumption withdrawal uses Form 7501 or its electronic equivalent; direct or indirect exportation generally uses a Part 18 in-bond application; transportation to another port is allowed only when final consumption or export withdrawal can be completed there before the warehousing period expires. Merchandise is not released merely because a withdrawal was filed: the approved permit evidences CBP authorization. Current law was reviewed on 2026-08-18 against the eCFR text current through 2026-08-14. For the October 2026 CBLE, answer from the exam-designated 2025 CFR edition when its wording or numbering differs from live law. Do not infer eligibility, release, or mastery from the shortcut.

Frequently asked questions

Which fact controls first for Choose who may withdraw and which route applies?

Begin with the chapter objective and the legally controlling facts, not with the desired commercial result. Identify the person with the right to withdraw and select the consumption, transportation, or exportation procedure. Then use 19 CFR 144.31-144.39 and the remaining cited sources to test every required element before calculating or filing.

Where should I verify Choose who may withdraw and which route applies for the exam and live work?

For the October 28, 2026 CBLE, use the designated exam source card and pinpoint 19 CFR 144.31-144.39. For live work, separately verify the dated current source cards for this chapter as of the transaction date; a current statute, eCFR, HTSUS, recordation, or agency guide does not silently amend the exam edition.

Official sources and editions

Key Terms

Bonded Warehouse|保税仓库
Five-Year Limit|五年期限
Warehouse Withdrawal|仓库提货
Class 2/3 Warehouse|第 2/3 类仓库
Back to Knowledge BaseUpdated 2026-04-09