Export

Questions and answers about Export

  • RECORDKEEPING IN ROUTED TRANSACTIONS

    QUESTION: We certain scenarios for routed transactions (where the customer is appointing the freight forwarder) we have problems getting the customer’s forwarder to provide us with the bill of lading created for the export.   If it’s a routed transaction, do we need to obtain a copy of the bill of lading? ========== Answers: The […]

  • ZTE EXPORT LICENSE

    QUESTION: The General Export License for ZTE Corp expires on 2-27-17, I have not seen anything on what BIS plans to do with them. Will they extend the license or remove them from the Entity List? ========== Answers: The Temporary General Export License for ZTE has been extended to now expire on March 29. 2017. […]

  • ROUTED EXPORT TRANSACTIONS

    QUESTION: For routed exported transactions (those shipments where our customer selects the freight forwarder), my company has had a past policy of filing the EEI and providing that info to customer’s forwarder.   I feel that this a non-value add process.  Our products are NLR and we don’t have duty drawback opportunity.   With current […]

  • DCS FOR INTANGIBLES

    QUESTION: In regards to the revised destination control statement in effect November 2016, it is noted that the exporter must incorporate the statement as an integral part of the commercial invoice whenever items on the CCL or USML are shipped (i.e. exported in tangible form).   My question pertains to intangible exports.  We normally would […]

  • LATE EEI FILINGS

    QUESTION: Once in a great while our export audit will uncover a shipment were no EEI was filed (usually routed, which we audit 100%).  We request the authorized filer to immediately file EEI.  The last 2 times the filer has insisted that ACE will not allow them to back-date the filing to the actual date […]

  • RPS SCREENING FOR PUERTO RICO

    QUESTION: We are in the process of automating our denied party screening for exports.  Our company regularly ships to Puerto Rico, which is technically not considered an export but does require EEI filing.  Is real-time denied party screening required for exports to PR?  Is there anything in the CFR or any supporting literature? ========== Answers: […]

  • ACE ROUTED EXPORT DISCREPANCY

    QUESTION: I just completed and audit of transactions showing in my exporter ACE report AES-202. The routed transaction indicator states “N”, but the actual ITN document from the forwarder shows that it was filed as routed. Has anyone else experienced this problem and if so, what is the cause and the solution? ========== Answer: So […]

  • EXPORT REPORTING GROSS MASS

    QUESTION: We have changed our processes in order to get the additional data for verified gross mass prior to export from the United States. A freight forwarder is telling us that the US does not require us (as the shipper/exporter) to report on verified gross mass.  Now questions are coming up the need to continue […]

  • POA FOR EEI FILING

    QUESTION: Do member USPPI’s seek to obtain from the FPPI in a routed export the authorization to be its US agent to file the EEI? ========== Answers: No, we don’t. We just don’t call it a routed export – we retain the right to file the EEI and we require the customer’s agent to provide […]

  • EFFECTIVE USAGE OF DDP

    QUESTION: My concern of using DDP shipments for US Export is that the USPPI now becomes the IOR in the foreign destination and is responsible for clearance. This creates risk for the USPPI from a compliance perspective because this would require a Foreign Power of Attorney (FPOA) to a broker in the foreign destination to […]

  • EAR SEC 758.3(b)

    QUESTION: How many USPPI’s obtain documentation of EAR Sec. 758.3(b) assumption of licensing authority from the FPPI in routed transactions? ========== We have wording on our end use / end user forms stating the FPPI is responsible for any license determination.  With that said, almost 99% of my exports are EXW and routed transactions.  I […]

  • SUFFIX FOR EEI AND ACE REPORTS

    QUESTION: Our company exports and files the EEI from different locations with same EIN, when we obtain the export reports from ACE it is a lot of work to identify the export location because it the same EIN. One of the suggestions from the compliance team is to identify each location with a suffix example:  […]