QUESTION: US Company A owns raw material stored at the contract manufacturer, US Company B. At the instruction of US Company A, US Company B prepares a shipment to export some of the raw material to Europe. US Company B prepares the commercial invoice and US Company A isn’t mentioned on the invoice. […]
Question:My company is selling to a related company in France, who in turn is selling to a related party in Israel. Israel is contracting the freight forwarder and my company in the U.S. is shipping direct to Israel. As this is a routed transaction, will my company need written authorization (as required by 15 CFR […]
Question:We are being asked to look into establishing an export consolidation center in the US. In addition to consolidating our own exports, our foreign related entities would order products from US-based third party suppliers and instruct them to ship to the consolidation center where their goods would be consolidated with ours. We have brought up […]
Question: Determination of the USPPI is still a bit of a challenge for me. Census states that the USPPI is “The person in the United States that receives the primary benefit monetary or otherwise of the export transaction.” According to the ICPA database, Mr. Jerry Greenwell from Customs (now retired) was famous for saying, “He […]
Question: I’d like to ask the membership about Export POA and Written Authorizations for EEI filings on behalf of USPPI. Almost all our Intl transactions to our membership are Routed Export Transactions were Foreign member nominates US forwarder to act on their behalf. My company is the USPPI on transaction where product is […]
Question: First let me describe the situation: We have a sister plant in Europe. They order their own parts directly on North America Suppliers. When the Suppliers complete the orders, they ship the product to our export freight forwarders warehouse for consolidation loading into one container. We at times will have 50 Suppliers shipping […]
Question: A question, how many have routed transactions/shipments where the FPPI’s forwarder actually refused to do the necessary paperwork so that they could file the AES for the FPPI? I am told they have refused to, because they have downsized so much, they don’t have the manpower to do so. And so they […]
Question: Scenario 1: We have customer owned equipment in our warehouse. We are shipping it to an overseas location to a 3rd party destination for testing. Since the equipment is customer owned and there is no sale, is the customer the USPPI with us being their “authorized agent”? There is no sale in this situation […]
Can anyone provide a reference that clearly states whether the USPPI in a routed transaction is responsible for keeping a copy of the SED, or transamission record, and/or the export BL? In other words, what are the recordkeeping requirements for the USPPI in a routed export transaction both under the EAR and the FTSR? Finally, […]
My company utilizes a thrid party vendor to package and label material for clinical trial materials. The third party then prepares the material for export. My company owns the material while it is being packaged and labeled. For export purposes, I maintain that my company is the USPPI for these shipments. I would like to […]
When we ship product to unrelated customers in Mexico, we are usually instructed to deliver the goods to a forwarder/broker in Laredo. The customer takes it from there. Our company sees this as a domestic transaction but I know this is a routed export transaction and frowned upon by U.S. Census Bureau. But it seems […]
I have an Export / USPPI question. We have transactions where we negotiate a purchase of goods (non licensed) from a US company to our Canadian entity. The goods are produced in Latin America and are delivered to a consolidation point in Miami by the US vendor. In Miami, the Canadian entity takes ownership and […]
