Routed export transactions always seem to be a hot topic. We receive numerous questions via our call center, webinars and seminars as companies look to better understand their roles and responsibilities to remain compliant.

The Foreign Trade Regulations (FTRs) define a routed export transaction as a transaction in which the Foreign Principal Party in Interest (FPPI) authorizes a U.S. agent to facilitate export of items from the United States on its behalf, and prepare and file the Electronic Export Information (EEI). In this type of transaction, the FPPI is controlling the movement of the goods.

Advice for ALL Parties in a Routed Export Transaction:

• Communication. Make sure communication is clarified and understood between all parties participating in the transaction.
• Documentation. Keep all documentation, such as emails, invoices and phone calls on all export transactions for five years from the date of export. 
• Appropriate authorization. Obtain a Power of Attorney (POA) or written authorization from the FPPI. The POA or written authorization should not be provided by the U.S. Principal Party in Interest (USPPI) in a routed export transaction.

Advice for the USPPI in a Routed Export Transaction:

• If possible, request to file the EEI:
  • If filing, obtain a POA or written authorization from the FPPI before filing the EEI.
• If the FPPI authorizes a U.S. agent to file the EEI:
  
  • Provide the data elements listed in section 30.3(e)(1)(i) through (xii) of the FTR to the U.S. authorized agent.
  • Request a copy of the data elements you provided to the U.S. authorized agent filed in the Automated Commercial Environment (ACE) as well as request the Internal Transaction Number (ITN), date of export and filer name.
  • Request a copy of the authorized agent’s POA or written authorization from the FPPI.
  • Sign up for ACE Export Reports. The USPPI can access ACE Report 203 for routed transactions to obtain a copy of the data elements submitted through the ACE along with the ITN, date of export and filer name. More information on accessing ACE reports can be found here.

Advice for the U.S. Authorized Agent in a Routed Export Transaction:

• Obtain a POA or written authorization from the FPPI before filing the EEI.
• Obtain the data elements listed in section 30.3(e)(1)(i) through (xii) of the FTR from the USPPI.
• If you are having trouble obtaining information from the USPPI, refer them to section 30.3(e)(1) of the FTR so the USPPI will know the law requires this information. The FTR is located here. If you need further assistance, please call the Trade Regulations Branch staff and we may be able to assist.
  
• Provide the USPPI with a copy of the POA or written authorization from the FPPI, a copy of the data elements provided by the USPPI that were submitted through ACE along with ITN, date of export and filer name. Authorized agents should use this as a best practice, but it is only required if requested by the USPPI.

For regulatory questions, contact Trade Regulations Branch at 1-800-549-0595, Option 3. For questions and more information on accessing ACE Export Reports, contact the Trade Outreach Branch at 1-800-549-0595, Option 5.

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