Current subscribers of the Import-Export Email Discussion List may have noticed a recent posting about routed export transactions. The individual who had posted his question was unsure of the responsibilities of all parties involved in the transaction.

While conducting an export transaction, the foreign purchaser, or foreign principal party in interest (FPPI), may request that their merchandise be delivered to another location within the United States for retrieval by a freight forwarder or other agent who has been contracted by the foreign purchaser to export the merchandise from the United States.

Since the foreign purchaser, in this instance, has contracted the services of a freight forwarder or other agent to facilitate the exportation of their merchandise, the transaction could be deemed a routed export transaction.

When routed export transactions were first introduced as a method of conducting an export transaction, there was a lot of confusion over the responsibilities of all parties involved in the transaction. In response, the federal government issued regulations that detailed the responsibilities of those parties.

Those federal regulations identify the seller of the merchandise as the U.S. Principal Party in Interest (USPPI) and the foreign purchaser of the merchandise as the FPPI.

In the event that the freight forwarder or other agent will be completing and submitting a Shipper’s Export Declaration via the Automated Export System on the behalf of the FPPI, the duly authorized freight forwarder or other agent must obtain a power of attorney or other written authorization from the FPPI.

The USPPI is not required to provide the authorized freight forwarder or other agent with a power of attorney or other written authorization in the case of a routed export transaction. However, the USPPI must provide the following data elements to the authorized freight forwarder or other agent:

• The name, as well as, the address of the USPPI;


• The employer identification number or other tax identification number of the USPPI;


• The point of origin for the merchandise awaiting exportation;


• The appropriate merchandise code, Domestic (D), Foreign (F) or Foreign Military Sale (M);


• The appropriate Schedule B number;


• The appropriate Schedule B description of commodities;


• The appropriate quantity and unit of measure;


• The appropriate value; and


• The appropriate export control classification number (ECCN) or enough technical information to determine the ECCN.

The FPPI’s freight forwarder or other agent needs these data elements to properly facilitate the exportation of merchandise as well as electronically file a complete and accurate Shipper’s Export Declaration through the Automated Export System.

Upon written request by the USPPI, the authorized freight forwarder or other agent of the FPPI may provide a copy of the power of attorney or other written authorization that has been furnished by the FPPI. It is highly recommended that the USPPI retain this documentation as part of their permanent file for the FPPI.

Although the FPPI’s freight forwarder or other agent is undertaking the responsibility of filing the appropriate export documentation, the USPPI still has other export compliance obligations such as checking the foreign purchaser’s information against various governmental restricted party lists for potential prohibited end users, and looking for any red flags that may indicate prohibited end use of the merchandise undergoing exportation. Equally important the USPPI must determine whether or not an export license is required for the merchandise.

( linda )22 Feb,2012

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