Question: When we sell and export product(s) to our subsidiaries overseas we are the USPPI and our subs are the FPPI. For EEI reporting we report our subs as the FPPI/ultimate consignee and the destination is typically a dedicated storage facility. We do not typically know who or where they will sell to at the […]
Question: 15 CFR 30 defines a routed transaction when an FFPI authorizes an agent to prepare and filing the EEI. If the authorized agent does not have a power of attorney or written authorization from the FPPI to file the EEI, it’s my understanding this is not a routed export because the transaction can only […]
Question: Is there a way to confirm an ITN for an EEI filing? For example, in a routed-export we received an ITN from a customer’s forwarder but cannot find it in our ACE data. I’m looking for a way to confirm that the ITN which we were provided is legitimate. Answer 1: There is something […]
Question: How is “air, containerized” to be applied for the EEI? The FTR defines container and containerized shipments. Do van-type containers fly via air? Or, are ULD types PMC and LD-1 considered as a container for the EEI? Answer 1: The FTR refers to ULDs for air shipments. For the most part, shippers don’t stuff ULDs […]
Question: §30.3 (e)(1) cites the USPPI is responsible to provide value as one of the many data elements in a routed export transaction where the FPPI has authorized an agent to file the EEI. §30.1 (c) defines value as The selling price (or the cost if the goods are not sold) in U.S. dollars, plus inland or […]
Question: I’d like to know from the community who you’d assign as the USPPI (US seller or US buyer) when EEI is required under below two scenarios: 1) US seller sells to US buyer in a domestic banking transaction and exports the order directly to US buyer’s overseas customer using US buyer’s small pack carrier […]
Question: If a foreign customer has agreed to an Ex Works transaction, it has agreed to accept responsibility to obtain any export license or other official authorization to carry out the export of the goods. However, does the fact that the above is true = a Routed Transaction? I have clients and one forwarder who […]
Question: My customer is auditing their filings on all exports and paying close attention to the routed shipments and finding a lot of fields are blank (such as value). They began going to the forwarders and explained they are missing information. The forwarders are claiming they are inputting all information into AES when they are […]
Question: We are a global company with locations in various countries. In this scenario, our Australian company (A) makes a sale to a customer in China (company C) and contracts with our US entity (Company B) to build and ship material directly to China (drop ship). However, in many cases, Australia allows the customer in […]
Question: What would the appropriate EEI exemption be for documents being sent Internationally to an unrelated party? Various documents could include contracts, leases, terminations, etc. Answer 1: We do not file AES for documents. Answer 2: Documents/technical data exports (even those that are exported under a license) are not subject to EEI because they are […]
Question: We, U.S. company are purchasing Tooling Molds from a U.S. company and will have the Tooling Mold company ship then to VN. We will arrange the shipping but unsure if we should file or if the Tooling Mold company should file. This is us making a purchase from them but we are arranging the […]
Question: Our warehouse operator employees use our ACE account to file the EEI /AES. Do we have to have POA or authorization to do so? Answer 1: Interesting question. A POA, needs to be signed by an officer of the company. Or it can be signed by an employee who is “duly authorized” by an […]
