Routed export transactions are a much discussed topic. Therefore, we are revisiting this blog topic to give some helpful tips on remaining compliant if you’re involved in a routed export transaction. We’ll also take a look at an example. For those not familiar with routed export transactions, it is when the Foreign Principal Party in Interest (FPPI) directs the movement of the goods out of the U.S. and authorizes a U.S. agent to file the Electronic Export Information (EEI) on their behalf.
Below are some helpful tips to keep in mind:
- Communication is key! Having conversations with all parties involved before the transaction occurs will make a difference in understanding roles and responsibilities to prevent filing errors in the Automated Export System (AES);
- Refer to Sections 30.3(e), (e)(1) and (e)(2) of the Foreign Trade Regulations (FTR) for the definition and more information on the responsibilities of the parties involved in a routed transaction;
- Utilize the Census Bureau resources; and
- View sample templates for the power of attorney and written authorization on our website here or here.
Routed Export Transaction Example:
A U.S. Principal Party in Interest (USPPI) sells two paintings to a FPPI located in Italy. Keep in mind, the USPPI is defined as the person or legal entity in the U.S. that receives the primary benefit, monetary or otherwise, from the transaction. The FPPI instructs the USPPI to send the paintings to an agent located in Florida. The FPPI authorizes the agent to file the EEI in the AES on their behalf and ship the goods to Italy. In this example, each party has important responsibilities that are outlined below.
- Provides the agent, who is authorized to file the EEI, with a power of attorney or written authorization, the authorization comes after the FPPI provides the POA or written authorization.
- Provides the agent with the data elements, such as Schedule B number, value, quantity, etc., specified in Section 30.3(e)(1) of the FTR.
- Retains documentation to support the information provided to the authorized agent for five years from the date of export.
- Requests a copy of the data elements that were filed in the AES and the power of attorney or written authorization.
- Ensures that a power of attorney or written authorization is received from the FPPI.
- Files the EEI in the AES.
- Provides the Internal Transaction Number or exemption code if filing is not required to the carrier.
- Retains documentation pertaining to the shipment for 5 years.
- If requested, provides the USPPI with a copy of the USPPI data elements that were filed in the AES and the power of attorney or written authorization from the FPPI. For further questions, please contact the Trade Regulations Branch (TRB) at 1-800-549-0595, option 3 or email us at email@example.com