Exporting From the US and the USPPI

With President Obama’s export initiative in place, a greater focus is on sales by US sellers to the foreign marketplace.  One important party in these transactions is the person or entity that would be considered the US Principal Party in Interest (USPPI) in export transactions, and particularly so when considering the filing the electronic export information (EEI), which is the export declaration made to the US Census Bureau through its AES Direct website. 

By definition, the USPPI is that who receives the primary benefit of a transaction, be it monetary or otherwise.  This may be the seller of the product or the manufacturer when it sells its goods directly to an entity in a foreign area. 

There are however, many variations for which determining the definition of the USPPI turns, which depends on what their involvement in the transaction is.

If a U.S. manufacturer sells goods as a domestic sale to a U.S. buyer (wholesaler/distributor) and that U.S. buyer sells the goods for export to a FPPI, then the U.S. buyer (wholesaler/distributor) must be listed as the USPPI in the EEI.

If a U.S. order party directly arranges for the sale and export of goods to a foreign entity, then the U.S. order party must be listed as the USPPI in the EEI.

If a customs broker is listed as the importer of record when entering goods into the United States for immediate consumption or warehousing entry, then the customs broker may be listed as the USPPI in the EEI if the goods are subsequently exported without change or enhancement.

If a foreign person is listed as the importer of record when entering goods into the United States for immediate consumption or warehousing entry, then the customs broker who entered the goods, may be listed as the USPPI in the EEI if the goods are subsequently exported without change or enhancement.

Understanding who the USPPI actually is matters, not solely in your typical export transaction, but also for identifying the record keeping requirements of a USPPI in the case of a “routed shipment.”  For more information about this, click here.

Questions/comments?  Post below or email me at clark.deanna@gmail.com