- Understand your role as an USPPI if you handle export transactions…
- Review the Quick Checklist…
- ICAT Logistics DTW will train you and walk you through the process…
If you or your company benefit from an export transaction, the Foreign Trade Division of the U.S. Census Bureau defines you as U.S. Principal Party in Interest (USPPI) — a role that comes with a number of significant responsibilities.
A USPPI’s duties help ensure government regulators and your freight forwarding partner that you are being transparent and properly identifying and handling the goods you are selling outside of the country.
What follows is a cursory outline of your role as USPPI.
AS USPPI, WHAT DO I NEED TO DO?
Begin by determining which government agency controls your
export and if applicable, what regulations govern it.
Here are possible options:
- The Export Administration Regulations (EAR)
- U.S. Department of State Directorate of Defense Controls International Traffic and Arms Regulations (ITAR)
- Nuclear Regulatory Commission (NRC), Drug Enforcement Administration (DEA), or Bureau of Alcohol and Tobacco & Firearms (BATF).
- You can self-classify, or
- Submit a Commodity Jurisdiction Request and let the U.S. Department of State’s Directorate of Defense Trade Controls determine whether your shipment is subject to export licensing rules. You will need to have a thorough description of the freight, including such information as its special or unique uses, value, origin, funding history, and other identifying characteristics. Complete directions are available on the site, as well as a contact for additional information and assistance.
- Some export items require an Export Control Classification Number (ECCN) which may be found on the Commerce Control List to identify items for export control that have more than one use.
DOES MY EXPORT REQUIRE A LICENSE?
- As USPPI you are required to determine whether your export freight must be licensed and that will depend on its classification, technical characteristics, destination, end-user, and end-use.
- Licenses may be required under EAR or ITAR, and it is worth noting that exporters who do not accurately identify and use licenses or license exemptions may face civil and criminal penalties. In fact, federal regulators closely monitor shippers who are exporting and fine them when they are not in compliance with existing regulations.
IS MY COMMODITY:
- On the U.S. Munition List (USML)?
- Subject to the EAR?
- On the Commerce Control List (CCL)?
HAVE I DETERMINED:
- If General Prohibitions 4-10 apply?
- Who will be the end-user and what the end-use of my commodity will be
- The disposition of my customer against Bureau of Industry and Security (BIS) guidance and reviewed for “Red Flags?”
- If all parties to the transaction have been screened?
- If I am shipping to a destination that is of concern because it is embargoed, sanctioned, or otherwise in question?
- If I need a BIS License?
- If my commodity qualifies for an EAR exception?
- If any other government regulations apply?
- There have been anti-boycott language or restrictive trade practices that may apply?
- I have given my forwarder the information needed and written authorization to file Electronic Export Information (EEI) on my behalf?
Depending on the commodities you are exporting, your role as exporter and USPPI may be complex or straightforward. But it is not a role you can afford to take for granted.
Although you alone will be ultimately responsible for how you meet your USPPI responsibilities, with decades of experience in the field, ICAT Logistics DTW will help train you and walk you through the process you must follow to be a successful exporter and meet your USPPI responsibilities.
PLEASE NOTE: If you are new to exporting, or want to refine your USPPI skills, ICAT Logistics DTW can help. We offer training to our clients to help them understand their USPPI roles and responsibilities.
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