Cite as: 507 U. S. 60 (1993)
Opinion of the Court
customs bonded warehouse scheme, is so pervasive that it demonstrates a federal purpose to occupy the field of container regulation and taxation. We doubt that the container regulatory scheme can be considered as pervasive as the customs warehouse scheme. The latter provides for continual federal supervision of warehouses, strict bonding requirements, and special taxing rules, see 19 U. S. C. §§ 1555 and 1557; 19 CFR pt. 19 (1992), whereas the former is limited more to the general certification and taxing of containers, see 19 U. S. C. § 1322; 19 CFR §§ 10.41a and 115.25-115.43 (1992). Even if Itel were correct on this point, however, we have not held that state taxation of goods in bonded warehouses is pre-empted by Congress' intent to occupy the field of bonded warehouse regulation. In fact, in R. J. Reynolds we specifically held that the bonded warehouse statutes and regulations did not evidence such a purpose. 479 U. S., at 149. So, too, we cannot conclude that in adopting laws governing the importation of containers Congress intended to foreclose any and all concurrent state regulation or taxation of containers.
The precise federal policy regarding promotion of container use is satisfied by a proscription against taxes that are imposed upon, or discriminate against, the importation of containers. We find that Tennessee's general sales tax, which applies to domestic and foreign goods without differentiation, does not impede the federal objectives expressed in the 1972 and 1956 Container Conventions and related federal statutes and regulations.
IV
A
Itel's third challenge to Tennessee's tax on container leases is that the tax violates the Foreign Commerce Clause as interpreted by Japan Line. U. S. Const., Art. I, § 8, cl. 3. We began our analysis in Japan Line with a reformulation of the Foreign Commerce Clause test:
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