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Responsibilities in an Export Transaction
Regulation: 15 CFR 30: Foreign Trade Regulations
When an export is being arranged from the United States it is important that all applicable export regulations are followed. Certain exports require that an Automated Exports System entry (AES) be filed.
This publication will define important terms for the export process, and will list the responsibilities of the parties involved in a US export.
Key Terms
EEI: The information that is filed via AES is known as the Electronic Export Information or (EEI). EEI is needed under the following circumstances:
• Shipment of merchandise under the same HTS/Schedule B commodity number is valued at more than US$2,500 and is sent from the same exporter to the same recipient on the same day. (Note: Shipments to Canada are exempt from this requirement.)
• The shipment contains merchandise, regardless of value, that requires an export license or permit.
• The merchandise is subject to the International Traffic in Arms Regulations (ITAR), regardless of value.
• The shipment, regardless of value, is being sent to Cuba, Iran, North Korea, Sudan or Syria.
• The shipment contains rough diamonds, regardless of value USPPI: US Principal Party in Interest is the person in the United States that receives the primary benefit monetary or otherwise of the export transaction.
• U.S. Seller (wholesaler/distributor) of the merchandise for export.
• U.S. Manufacturer if selling the merchandise for export.
• U.S. Order Party - Party who directly negotiated between the U.S. seller and foreign buyer and received the order for the export of the merchandise.
• Foreign Entity if in the U.S. when items are purchased or obtained for export.
FPPI: Foreign Principal Party in Interest is the foreign entity that has contracted with the USPPI to obtain the merchandise (the FPPI may be shown on the transportation
documents as the end user of the goods).
Routed Transaction: A Routed Transaction is an export in which the FPPI authorizes a U.S. agent to facilitate export formalities on their behalf. The FPPI controls the movement of the goods out of the U. S.
• The FPPI provides the authorization to a U. S. agent to prepare and file the EEI.
• The USPPI provides information to the U. S. agent regarding the shipment or can file the EEI, if they have received authorization from the FPPI.
Responsibilities in an Export Transaction
USPPI Responsibilities:
• Act on his own behalf and file the EEI
• Appoint an authorized U.S. agent to prepare and file the EEI on its behalf
• Provide a power of attorney or written authorization to the authorized U.S. agent
• Make a License Determination
• Retain documentation
Authorized Agent Responsibilities:
• Obtain the authorization from the USPPI
• Provide transportation data
• Provide the USPPI with export information that it provided as submitted through the AES, if requested
• Retain documentation
Responsibilities in a Routed Transaction
USPPI Responsibilities
• File on behalf of the Foreign Principal Party in Interest (FPPI), if a power of attorney or written authorization is received.
• Provide authorized U.S. agent of the FPPI with specific export and licensing information.
• Upon request, the USPPI can receive a copy of the required export information that was submitted to the authorized U.S. agent to file.
• Obtain in writing from the FPPI, that the FPPI assumes responsibility for licensing functions(See EAR 758.3)
• Retain documentation
Agent Authorized by FPPI
• Obtain a Power of Attorney (POA) or written authorization from the FPPI
• Upon request, provide the USPPI with a copy of the POA or written authorization provided by the FPPI
• Prepare and file the EEI record
• Upon request, provide the USPPI with a copy of the data elements provided by the USPPI
Agent Authorized by USPPI
• Obtain a POA or written authorization from the USPPI
• Prepare and file the EEI record
• Upon request, provide the USPPI with a copy of the data elements filed
• Maintain documentation