Did you know that the U.S. Customs Broker can be listed as the USPPI when reporting export information  in the AES? Well, as Sean mentioned in his October 13, 2010 blog entitled “Who is the USPPI Anyway?“ the U.S. Customs Broker may be reported as the USPPI if they are listed as the importer of record when clearing goods into the United States. Likewise, if a foreign person or entity is listed as the importer of record when entering goods into the United States, the U.S. Customs Broker may be listed as the USPPI in the EEI, if the goods are subsequently exported without change or enhancement. Let’s look at a couple scenarios:

• Goods formally enter into the United States and a customs broker is listed as the importer of record. The goods are then subsequently sent to a forwarding agent for immediate export to a foreign buyer. Because there is no U.S. entity that takes ownership of the goods, the customs broker is listed as the USPPI. (Refer to FTR 30.3 (b)(2)(iv))
• A Canadian company is listed as the importer of record; however, a U.S. customs broker enters the goods on behalf of the foreign entity. The goods are then subsequently sent to a forwarding agent for immediate export to a foreign buyer. Because there is no U.S. entity that takes ownership of the goods and a foreign entity is listed as the importer of record, the customs broker who declared the goods would be listed as the USPPI. (Refer to FTR 30.3 (b)(2)(v))

In order for these shipments to be properly exported from the United States, it is important to remember that the USPPI or the U.S. Authorized agent must submit accurate, timely, and complete information to the AES.

For more information about the responsibilities of the USSPI, and who can be the USPPI in an export transaction, please refer to section 30.3 of the Foreign Trade Regulations.