In a “routed shipment” the “authorized agent” is not required to give the U.S. Principal Party in Interest (USPPI) the export data. This data was formerly collected in a Shipper's Export Declaration (SED) and is now mandated to be filed through the Automated Export System (AES) or AESDirect. This raised the question of which records must be retained by a USPPI in a routed shipment.
A routed shipment occurs when there is a foreign buyer that makes a purchase from a domestic seller here in the U.S. Rather than have the domestic seller arrange for the transport of the goods to the foreign destination, the foreign buyer (aka, the "Foreign Principal Party in Interest" (FPPI)) finds its own U.S. agent to assist it with the export.
For this type of transaction, the FPPI authorizes a U.S. agent (Authorized Agent) to facilitate the export of items from the U.S. and prepare and file electronic export information (EEI). This electronic export data is filed in AES.
For a routed shipment, the USPPI must retain documentation to support the information provided to the Authoized Agent for preparing the EEI, and provide the agent with certain information to assist in preparing the EEI. This information includes:
(i) Name and address of the USPPI
(ii) USPPI's EIN or DUNS
(iii) State of origin (State)
(iv) FTZ if applicable
(v) Commercial description of commodities
(vi) Origin of goods indicator: Domestic (D) or Foreign (F)
(vii) Schedule B or HTSUSA, Classification Commodity Code
(viii) Quantities/units of measure
(ix) Value
(x) Export Control Classification Number (ECCN) or sufficient technical information to determine the ECCN
(xi) All licensing information necessary to file the EEI for commodities where the Department of State, the Department of Commerce, or other U.S. government agency issues a license for the commodities being exported, or the merchandise is being exported under a license exemption or license exception.
(xii) Any information that it knows will affect the determination of license authorization
The Authorized Agent in a Routed Transaction is responsible for filing the EEI accurately and timely and must retain the documentation to support the EEI reported through AES which includes the following data elements:
(i) Date of export.
(ii) Transportation Reference Number.
(iii) Ultimate consignee. (vii) Country of ultimate destination.
(viii) Method of transportation.
(ix) Carrier identification and conveyance name.
(x) Port of export.
(xi) Foreign port of unloading.
(xii) Shipping weight.
(xiii) ECCN.
(xiv) License or license exemption information.
These regulations provide that upon request, the Authorized Agent shall provide the USPPI with the data elements above. The reality however, is that even upon repeated request, this information may never be received by the USPPI.
Therefore, under the regulations the USPPI may request a copy of the electronic record or submission from the U.S. Census Bureau. Keep in mind however, that the Census Bureau's retention and maintenance of AES records does not relieve filers from requirements.
Questions or comments? Feel free to email me at clark.deanna@gmail.com
A routed shipment occurs when there is a foreign buyer that makes a purchase from a domestic seller here in the U.S. Rather than have the domestic seller arrange for the transport of the goods to the foreign destination, the foreign buyer (aka, the "Foreign Principal Party in Interest" (FPPI)) finds its own U.S. agent to assist it with the export.
For this type of transaction, the FPPI authorizes a U.S. agent (Authorized Agent) to facilitate the export of items from the U.S. and prepare and file electronic export information (EEI). This electronic export data is filed in AES.
For a routed shipment, the USPPI must retain documentation to support the information provided to the Authoized Agent for preparing the EEI, and provide the agent with certain information to assist in preparing the EEI. This information includes:
(i) Name and address of the USPPI
(ii) USPPI's EIN or DUNS
(iii) State of origin (State)
(iv) FTZ if applicable
(v) Commercial description of commodities
(vi) Origin of goods indicator: Domestic (D) or Foreign (F)
(vii) Schedule B or HTSUSA, Classification Commodity Code
(viii) Quantities/units of measure
(ix) Value
(x) Export Control Classification Number (ECCN) or sufficient technical information to determine the ECCN
(xi) All licensing information necessary to file the EEI for commodities where the Department of State, the Department of Commerce, or other U.S. government agency issues a license for the commodities being exported, or the merchandise is being exported under a license exemption or license exception.
(xii) Any information that it knows will affect the determination of license authorization
The Authorized Agent in a Routed Transaction is responsible for filing the EEI accurately and timely and must retain the documentation to support the EEI reported through AES which includes the following data elements:
(i) Date of export.
(ii) Transportation Reference Number.
(iii) Ultimate consignee. (vii) Country of ultimate destination.
(viii) Method of transportation.
(ix) Carrier identification and conveyance name.
(x) Port of export.
(xi) Foreign port of unloading.
(xii) Shipping weight.
(xiii) ECCN.
(xiv) License or license exemption information.
These regulations provide that upon request, the Authorized Agent shall provide the USPPI with the data elements above. The reality however, is that even upon repeated request, this information may never be received by the USPPI.
Therefore, under the regulations the USPPI may request a copy of the electronic record or submission from the U.S. Census Bureau. Keep in mind however, that the Census Bureau's retention and maintenance of AES records does not relieve filers from requirements.
Regarding records retention, a USPPI must retain documentation to support the information provided to the authorized agent for filing the EEI when it has authorized an agent to file the EEI on its behalf.
Questions or comments? Feel free to email me at clark.deanna@gmail.com
