Types of Export Transactions and Party Responsibilties
The two types of export transactions are standard transactions and routed transactions. Before assessing the actual type of transaction it is important to understand the parties in the transaction.
US Principal Party in Interest (USPPI)
This person or entity is the primary beneficiary of the transaction whether it is monetary or otherwise who is physically within the US. Non-monetary benefits may be the transport of goods from one facility to another without any type of payment to or from another. The USPPI may be a seller, manufacturer, order party or customs broker in the US as well as a Foreign entity who is physically in the US.
A party physically located in the US that obtains a power of attorney or written authorization from a USPPI or Foreign Principal Party in Interest to prepare and file the electronic export information (EEI). Written authorization or power of attorney can be granted for a set amount of transactions or time.
The entity that executes the movement of the goods. The carrier checks the documentation for the Internal Transaction Number (ITN) or exemption/exclusion citation. They are also tasked with writing the appropriate citation on the outbound manifest and relaying it to the Customs and Border Protection port director. The carrier may also need to inform the Automated Exports Systems (AES) of any transportation information changes.
Foreign Principal Party in Interest (FPPI)
The party abroad who purchases the goods to whom final delivery will be made.
The party in the delivery country who is affecting the delivery of the product to the ultimate consignee
The party that is located abroad and actually receives the export shipment in the final country. This party may be the FPPI
Types of Transactions
The USPPI controls the movement of the cargo in this type of transaction. The USPPI may file the EEI themselves or hire an authorized agent to do so. If the USPPI decides to file the EEI on their own they must check the license determinations for the goods being exported. Certain end-use activities for products require a license so it is important to ensure that both the cargo itself and its end use are adequately licensed.
The FPPI controls the movement of the cargo in this type of transaction. The FPPI will likely use an authorized agent to facilitate the export of the items through preparing and filing the EEI but may also authorize the USPPI to do so. It is important that the FPPI and the authorized agent agree upon who will do the AES filing because if left undone, the goods will not leave the US. The FPPI can use an authorized agent that is completely outside of the transaction to potentially hide an ultimate consignee who is not the FPPI from the USPPI. The FPPI may do this to avoid the potential of the USPPI selling directly to the ultimate consignee.
In this transaction the USPPI can request the data elements, a copy of the power of attorney or copy of the written authorization from the authorized agent. The agent must also provide the filing citation and exemption legend to both the USPPI and FPPI.
There is a greater burden on the USPPI to provide data and licensing information for the transaction. The information that needs to be given to the authorized agent includes:
•Name and address of USPPI •USPPI’s Employer Identification Number
•State of Origin • Free Trade Zone(if applicable)
•Commercial Description of Commodities •Quantities/Unit of Measure
•Origin of Good Indicator •Value and License Value
•Schedule B or Harmonized Tariff Schedule •All licensing information
•Export Control Classification Number
Notes about Transactions
Communication between all parties is important to avoid multiple filings which may cause complications with the export. Also, any documentation or information related to transactions should be kept for five years.
There is a wide range of resources and tools for any questions or to generally learn the methodology of exporting.
• Export Compliance Seminars • Domestic and International Trade Shows
• Training from Federal Agencies • Trade Webinars
• International Trade Help Line: 1-800-549-0595
Many instances of the resources listed above can be found here.
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