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Advanced Notice of Proposed Rulemaking: Request for Public Comments Regarding Standard and Routed Export Transactions

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An Advanced Notice of Proposed Rulemaking, or ANPRM, soliciting comments about routed export transactions was published on October 6, 2017. Routed export transactions are one of the most talked about subjects in the Foreign Trade Regulations. As a result, we want to give the trade community an opportunity to comment and provide feedback on routed export transactions before we publish a Notice of Proposed Rulemaking.

We are looking for feedback on the following questions found in the ANPRM:

1.      If you do not think the definition of a routed export transaction in 15 CFR 30.1 is clearly stated, then what definition of routed export transaction would you suggest?

2.      Should the Census Bureau modify the list of data elements at 15 CFR 30.3(e)(2) that the U.S. authorized agent is required to provide when filing the electronic export information? If so, what changes would you suggest?

3.      Should the Census Bureau modify the list of data elements at 15 CFR 30.3(e)(1) that the U.S. Principal Party in Interest (USPPI) is required to provide to the U.S. Authorized agent? If so, what changes would you suggest?

4.      The carrier’s responsibilities under the Foreign Trade Regulations, or FTR, are the same in both standard and routed transactions. Does the FTR clearly communicate these responsibilities? If not, what clarification would you suggest?

5.      The data elements that the USPPI and U.S authorized agent are required to provide are currently located in Section 30.3(e) of the FTR. However, additional data elements are needed to complete the Automated Export System filing. Below is a list of data elements that are required to be reported, but for which a responsible party is not listed. Please provide comments on which party, the USPPI or the U.S. authorized agent, should report these data elements.

Hazardous Material Indicator

Routed Export Transaction Indicator

KPC Number

FTZ Identifier

Vehicle Title Number

Related Party Indicator

Shipment Reference Number

Vehicle Title State Code

Export Information Code

VIN/Product ID

Filing Option Indicator


6.      Are the responsibilities of parties in a routed export transaction clearly stated? If not, what improvements would you suggest?

7.      How could we improve the process to authorize filing in a routed export transaction?

8.      How could the FTR be revised to align with the Bureau of Industry and Security’s Export Administration Regulations on routed export transactions?

9.      What changes would you suggest in Section 30.3 of the FTR that might improve the parties’ understanding of the requirements of a routed export transaction?

10.  What changes would you suggest in Section 30.3 of the FTR that might improve the parties’ understanding of their roles in a routed or standard export transaction?

Comments do not necessarily need to address the questions listed above. We welcome all feedback relevant to routed export transactions.

We hope you take the opportunity to participate in a dialogue with us by submitting comments during the 60-day comment period. To view the Advanced Notice of Proposed Rulemaking, please click here. To submit comments to us, please do so through the Federal e-Rulemaking portal by searching for RIN Number 0607-AA56 and clicking the “Comment Now!” button.

If you have any questions, please contact the Trade Regulations Branch at 1-800-549-0595, Option 3.

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Page Last Revised - October 8, 2021
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