Questions and answers about Export


    QUESTION: I have a dilemma in determining who should be the true exporter of record. My company has an office in West and East Coast.  The West Coast office is the physical distribution and export for two different divisions/product lines.  We have always exported under West Coast office address and TAX ID.  Internally we will […]

  • Obtaining export data of shipments from US to Canada

    QUESTION: My company imports into the US and then exports some of the products into Canada, so I want to look into setting up a duty drawback program.  To determine the potential refund amount, I can run the ACE ES-003 report to see the details of all our US imports, but how can I find […]


    QUESTION: Asking for any experience people are willing to share of interaction with Czech Republic Customs authorities about the declaration of Country of Origin (CoO) for materials being exported. I am aware of the requirement to declare accurate CoO and that this data is coming under more focus recently due to various trade sanctions. We […]

  • Origin for Export filing

    QUESTION: I know the rules require claiming both ‘D’ or ‘F’ for origin when items of the same HTS code are exported.  We manufacture and buy a bulk commodity, but do not have an inventory system to identify how much of the exported fungible good was from a foreign source or a domestic source. Is […]

  • In-bond movement and client privacy

    QUESTION: I have a client who is interested in finding cheaper options for transporting product to the Caribbean Islands from Panama. The client suggested to bring the containers to Miami, then transport it through a 7512 “in-bond’  to Everglade, FL where the product would be repackaged and sorted into different containers, then transported back to […]


    QUESTION: We buy products and parts from US vendors and need to export, and those civil products obviously belong to EAR99 and we don’t see any possibility of dual use. However, we have recently learned that the product contains a couple of circuit boards (PCB boards) which had hundreds of various electric components soldered on […]

  • Routed Export Transaction

    QUESTION: Company “A” is buying from Company “B” – Company “A” is exporting the goods to Company “C” overseas – In my experience Company “A” is the Exporter – Correct or incorrect? %%%%%%%%%% ANSWER: Maybe.  Maybe not.  Not quite enough information to go on.   Assuming both Company A and Company B are in the […]


    QUESTION: During a review of ACE Export reports we noticed that some “routed exports” were actually flagged as standard exports. Is this considered a “violation”, and do the EEI/AES filings on these exports need to be corrected to indicate that they were actually routed exports? Clearly this needs to be addressed with the FPPI and […]

  • Routed Export Transaction

    QUESTION: Company “A” is buying from Company “B” – Company “A” is exporting the goods to Company “C” overseas – In my experience Company “A” is the Exporter – Correct or incorrect? ========== Answers: If Company A and Company B are based in the same country and that sale is a domestic transaction, then it […]


    QUESTION: 15 CFR 30.6(a)(2) says the date of export is “date when goods are scheduled to leave the port of export on the exporting carrier that is taking the goods out of the United States.”  When a carrier rolls that date, is the filer obligated to amend the EEI with the revised date? More specifically, […]

  • FPPI in a Triangulated Shipment

    QUESTION: My company currently conducts “triangulated-shipments” in conjunction with our foreign affiliates. Example: Colombia affiliate orders products from my USA company. Products are shipped directly to the end customer in Ecuador. We provide our Colombia affiliate an inter-company invoice; they pay us. Colombia affiliate in turn provides Ecuador customer a separate commercial invoice for customs […]

  • Commercial Invoice Numbering Schemes

    QUESTION: We are looking to adapt an in house automated commercial invoicing system that will assign sequential commercial invoice numbers for each shipment/export made.  Are there “unique country exporting to” requirements behind the assigned commercial invoice numbers that anybody is aware? Example:  If you ship to a country throughout the year, the shipments to that […]