Do you control your exports? The annual Update conference in Washington DC typically hosts a roundtable discussion about Routed Exports. The consensus of the people in the know? Routed Exports? Don’t.
I stumbled across this last week and thought it worth the words to point to an the words of an expert in the area.
When it comes to filing the EEI, the FTR defines a “Routed Export Transaction” as “a transaction in which the FPPI authorizes a US agent to facilitate the export of items from the United States on its behalf and prepare and file the EEI.”
When your customer (the FPPI) has not provided you with written acceptance of licensing responsibility, then you are the “exporter” under the EAR and you must make the licensing determination.
But…read the whole thing. I’m tempted to quote it all. Don’t confuse your Inco Terms and your EEI filing requirements. FTR and EAR have two things in common: they’re both acryonyms, and both contain an “R.”
We’re regular attendees at the US Government’s Update conference. Look for us at the next one!
Curious about how Global Wizard can help you streamline your exporting operations without getting in the way of your established best practices? Contact Us!