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Clarification Of Routed Export Transactions

Posted By rosannatorres On April 1, 2010 @ 7:21 am In Foreign Trade Regulations | 52 Comments

By: Justin Jenkins

Understandably, this concept of a routed transaction is risky and generates many questions. Let’s try to answer those questions and mitigate the risk.

The Dynamics of Routed Transactions shown with arrows and party names. [1]

The Foreign Trade Regulations (FTR) defines a routed export transaction as, “an export transaction in which the foreign principal party in interest (FPPI) authorizes a U. S. agent to facilitate the export of a shipment from the U. S. and to prepare and file electronic export information (EEI).” Routed export transactions are a risk in that these transactions shift the control of the movement of the goods and the filing of the EEI from the U. S. Principal Party in Interest (USPPI) to the FPPI. The FPPI directs the movement of the goods out of the U. S. and authorizes the U. S. agent to file the Automated Export System record for the shipment. Though the FPPI is “controlling” the export transaction, the USPPI is still responsible for providing their name, address, and all the commodity information to the filing agent (see FTR section 30.3(e) for a detailed listing of the items).

To ensure that the EEI is filed accurately and to reduce your risk in this type of transaction, you should ask the FPPI to authorize you to file the EEI.

Key points about routed transactions:

  1. The FPPI controls the movement of the goods out of the U. S.
  2. The FPPI provides the authorization to a U. S. agent to prepare and file the EEI.
  3. The USPPI provides information to the U. S. agent regarding the shipment or can file the EEI, if they have received authorization from the FPPI.

Routed export transactions can be challenging, but if you adhere the key points discussed above, you will mitigate the risk involved in these transactions.

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52 Comments (Open | Close)

52 Comments To "Clarification Of Routed Export Transactions"

#1 Comment By Carlos R. Maysonet On May 30, 2010 @ 7:00 pm

What is the meaning of POA?

#2 Comment By Global Reach Justin On June 1, 2010 @ 7:57 am

POA is the acronym for Power of Attorney.

#3 Comment By Taylor C On January 13, 2011 @ 3:27 pm

Per the above: “The Foreign Trade Regulations (FTR) defines a routed export transaction as, “an export transaction in which the foreign principal party in interest (FPPI) authorizes a U. S. agent to facilitate the export of a shipment from the U. S. and to prepare and file electronic export information (EEI).””
My question is if in contract of sale the USPPI assumes the responsibilty of Export Clearance but not to facilitate the export would this still be defined as a routed transaction? Does the USPPI still need to obtain a POA from the FPPI to file the AES?

#4 Comment By Global Reach Raemeka On January 18, 2011 @ 12:38 pm

In a routed transaction, the FPPI is determining how the goods will be exported from the U.S. Therefore, if the transaction does not meet the definition of how the FTR defines a routed transaction, then the transaction will be considered a standard export transaction. The contract of sale does not determine if the transaction will be routed.
Also, Per the FTR 30.3(e), Responsibilities of parties in a Routed Transaction, a POA or written authorization must be provided to the authorized agent or the USPPI to file the EEI from the FPPI. Therefore, yes, a POA must be provided to the USPPI from the FPPI to file the AES.

#5 Comment By Taylor C On January 26, 2011 @ 7:26 am

On the Census webpage there is an example for written authorization between the USPPI and an US Agent but not between an Agent and the FPPI or the USPPI and the FPPI. Is there another location that were an example can be found for these?

#6 Comment By Danielle R. On April 4, 2012 @ 1:26 pm

Is it only routed if the shipment meets both criteria? : 1:FPPI controls movement 2:FPPI authorizes agent to file EEI
For example: While we know sales terms don’t necessarily correlate whether it is routed or not, what do you make of this case: a shipment shipping under FCA terms, the USPPI would have responsibility for clearance while FPPI is controling the routing. Correct? Or is it routed because the FPPI is controlling the routing?
To sum up, my question is, which determines whether it is routed: who controls the routing or who authorizes the EEI? Or do both need to be controlled by the FPPI before the shipment is considered for being a routed transaction?

#7 Comment By Global Reach Omari On April 17, 2012 @ 9:12 am

There was a previous blog specifically written to clarify the responsibilities of parties in a routed export transaction. Please go to the following link for more details: [3]

#8 Comment By Steve On May 15, 2012 @ 10:33 am

It is understood that the USPPI will always be known as the shipper/exporter for obligations of the EEI filing in an Routed Export Transaction, however, is it also true that obligation of being shown as shipper/exporter does not exist for the USPPI when it comes to export documentation such as the ocean or air bill of lading ? In other words, the duly authorized US agent acting in behalf of the FPPI and who is facilitating the actual export should be indicated as the shipper/exporter, correct ?

#9 Comment By Javier On June 18, 2012 @ 4:09 pm

I need to know Who is going to be the shipper / exporter in the field of the exporter in a routed export transaction?

#10 Comment By Global Reach Sean On July 2, 2012 @ 7:31 am

The parties of the transaction do not change because it is a routed transaction. The USPPI is still the person or entity in the U.S. that receives the primary benefit from the transaction. For more information see section 30.3(b)(2) of the Foreign Trade Regulations.

#11 Comment By Jennifer On August 17, 2012 @ 5:49 pm

If a foreign buyer consolidates freight from more than one US seller, AES must be filed for each USPPI, correct? If a USPPI requests proof of AES filing (for routed transactions) and is not given the proof and suspects the filings may be incorrect, what liability do they have?

#12 Comment By Global Reach Omari On August 29, 2012 @ 8:10 am

@ Jennifer
Yes, you are correct. Based on your question, there would be multiple shipments if there are multiple US sellers, based on the definition of a shipment, one US seller shipping to one foreign consignee on one day, on one carrier. In a routed transaction, the US agent is required to provide a copy of data elements provided by the USPPI. It’s important for the USPPI to retain that documentation.

If you are having trouble getting documentation from the US agent, make sure you contact the Regulations, Outreach and Education Branch on 800-549-0595 Opt. 3. They can assist you.

#13 Comment By Elizabeth On August 30, 2012 @ 1:58 pm

We are the USPPI (a commercial EAR99 company), with a Korean customer. We have a shipment that is FOB, UNEX. UNEX is one of our vendors and is located in Korea as well. This shipment is considered a drop shipment from our vendor, however, our customer is going to arrange the pickup. Are we as the USPPI responsible for the Commercial Invoice and Packing List? Or just the Commercial Invoice?
I keep going round and round on who should supply what document.

#14 Comment By Global Reach Omari On September 13, 2012 @ 9:19 am

@Elizabeth
If the foreign party, the Korean customer is paying you for the product, then yes, you are the USPPI. However, the Foreign Trade Regulations do not govern the invoice or packing list related to the export transaction, only what’s reported in the AES. You may want to touch base with your local Customs office to get their advice as to which documents should be included with the shipment.

#15 Comment By Riau Daily Photo On December 30, 2012 @ 3:11 am

risks what happens if Routed Export Transaction is not done well

#16 Comment By Janie Kuebler On January 31, 2013 @ 3:59 pm

why is so hard to get the POA from the freight forwarder? Most of the US agent dont even know what I am talking about?

#17 Comment By Alex Alarcon On February 13, 2013 @ 2:36 pm

Would it still be considered a Routed Transaction if it’s an import into the USA? Given the USPPI would complete all shipping documentaiton for the shipper overseas.

#18 Comment By Global Reach Daniel On February 13, 2013 @ 3:12 pm

Hi Alex,

In this case, I think the concept of Routed Export Transaction is being misinterpreted. A Routed Export Transaction is when the Foreign Principle Party in Interest (FPPI) authorizes a U.S. agent (such as a freight forwarder) to facilitate the export of items (not import) from the United States and to prepare and file the Electronic Export Information (EEI) to the Automated Export System (AES). If you have any other questions regarding Routed Export Transactions, please call 1-800-549-0595, option 3 or e-mail [4].

#19 Comment By Janie Kuebler On February 13, 2013 @ 3:37 pm

To anwer to your question. If the USPPI assumes the responsibility of export clerance, it is not an routed transaction.

#20 Comment By Scott On February 14, 2013 @ 9:10 am

POA = Power of Attorney

#21 Comment By Gloria Dias On February 14, 2013 @ 9:16 am

Hello Carlos, it means Power of Attorney.

#22 Comment By JW Montgomery On February 19, 2013 @ 9:40 am

I am needing one simple clarification on this – if the FPPI has not legally authorized their Freight Forwarder/Agent in the U.S. to prepare and file AES via a POA then by definition I would NOT have a routed transaction, correct?

This would just be an standard export transaction where the FPPI’s Freight Forwarder moves the freight out of the U.S. but not until the USPPI or its agent pepares and files AES and provides the necessary export documentation to the FPPI’s Freight Forwarder.

#23 Comment By Andrew Harris On April 1, 2013 @ 6:39 pm

@JW Montgomery / Omari Wooden,

I also need clarification on this. If the FPPI has appointed a forwarder for shipment, I as the USPPI should ask for a copy of the POA granting that approval. If the forwarder does not have authorization within that POA (or none at all) am I then automatically authorized to complete the AES filing as the USPPI? Or are we both sitting ducks and can do nothing until that approval is granted by the FPPI? Furthermore, why does the USPPI need anyone’s permission to complete AES filing?….why doesn’t the regulation simply state that the USPPI may file if it so chooses in any situation? Why do we put that power in the FPPI’s hands? I just don’t understand why changes aren’t being made to alleviate confusion and work in favor of the USPPI to grant better control of export compliance from the US overall…

#24 Comment By Cedric Cita On April 19, 2013 @ 4:39 pm

In the case of a routed transaction where the FPPI is buying goods from several US SELLERs , is it possible to enter several ITN numbers in one bill of lading if all the goods have the same destination / consignee ? This is assuming that the US SELLERS ( USPPI) are in agreement and that their respective agent file on behalf of the FPPI.

#25 Comment By Rick A On May 21, 2013 @ 10:44 am

I have a question with reference to the preparation of the documents for a ROUTED TRANSACTION.
I already have the POA from the FPPI and the SLI from the USPPI need to prepare the ocean B/L.
So, In order for the shipment to be consider a ROUTED TRANSACTION does the FPPI need to appear as the shipper on the B/L? Can a shipment be considered a ROUTED TRANSACTION if the USPPI is the Shipper and the B/L is consigned to the FPPI’s agent at destination?

#26 Comment By Marge stucke On September 8, 2013 @ 5:28 pm

If The FPPI s forwarder files the AES on the shipment, how do we know if they we given the POA to do the filing , thus making it a routed shipment? Do we as the USPPI
Have to request a copy of this from the forwarder? And if they weren’t given a POA, and still file the AES ..it is a non-routed transaction, is that correct?

#27 Comment By Global Reach Daniel On September 17, 2013 @ 2:07 pm

@Marge,

Our Regulations, Outreach and Education Branch can assist you on this matter. I suggest contacting their call center at 1-800-549-0595, option 3.

#28 Comment By Vince Colgan On November 14, 2013 @ 11:09 am

In a routed transaction do I need to provide the US Agent with a Shippers Letter of Instruction? We do provide a commercial invoice which contains all the information needed for the AES filing. My interpretation is since the FPPI controls the shipment and has a POA with the US agent I should not have to provide an SLI.

#29 Comment By Global Reach Sean On December 26, 2013 @ 11:36 am

@Vince – Since this is a routed transaction and the foreign buyer has selected an authorized agent to file you are simply obligated to provide the applicable data elements listed in section 30.3(e) of the Foreign Trade Regulations.

#30 Comment By Traci On January 16, 2014 @ 3:16 pm

Is it still considered a routed transaction if the FPPI is providing to us, the USPPI, an account number for the shipper of their choice? This means they are controlling the movement of goods, right?

#31 Comment By Mariano Gutman On February 14, 2014 @ 12:28 pm

Can a US Authorized Agent give Logistic and Trading Services (purchase, sales, in bound transport and warehousing in behalf) to the FPPI against a trade/service fee, or it’s only for export purposes acting as a Freight Forwarder?

#32 Comment By Jack Locastro On February 18, 2014 @ 6:03 am

Could I please have the answer to Daniel R’s blog on April 4.

Quote – “Is it only routed if the shipment meets both criteria? : 1:FPPI controls movement 2:FPPI authorizes agent to file EEI
For example: While we know sales terms don’t necessarily correlate whether it is routed or not, what do you make of this case: a shipment shipping under FCA terms, the USPPI would have responsibility for clearance while FPPI is controling the routing. Correct? Or is it routed because the FPPI is controlling the routing?
To sum up, my question is, which determines whether it is routed: who controls the routing or who authorizes the EEI? Or do both need to be controlled by the FPPI before the shipment is considered for being a routed transaction?” – Unquote.

The FPPI in this case, cannot be expected to accept civil and criminal penalties as described in the ‘written authorisation’ form in connection to electronically transmitted information when under FCA terms it is the scope / responsibility of the USPPI to execute the EEI function.

#33 Comment By Global Reach Daniel On February 18, 2014 @ 8:47 am

@Mariano,
The Foreign Trade Regulations do not regulate what an authorized agent can and cannot do outside the scope of their responsibilities related to filing export information in the Automated Export System.

#34 Comment By Global Reach Daniel On February 18, 2014 @ 9:22 am

@Jack,
In a routed transaction, both must occur. The FPPI must facilitate the export and then authorize the USPPI or a U.S. agent to file the EEI. If the FPPI has not authorized a filer, however, that does not mean it is not a routed transaction. In that situation, the FPPI would have failed to meet their responsibilities and the goods could not be exported.

#35 Comment By KL On March 25, 2014 @ 10:22 am

In a routed transaction the FPPI authorizes the US agent to file the EEI and a POA must be on file between the FPPI and US agent and provide a copy to the USPPI upon request. Got that.

What I am confused about is I am the USPPI and the US agent is going to be entering into the AES my EIN and the data elements I provide to them. Is there a requirement for a POA between the USPPI and the US agent since the agent is using MY EIN? According to the Census guidance, there isn’t a requirement. Perhaps I am missing something?

#36 Comment By Eager to comply! On April 3, 2014 @ 6:09 pm

Question # 1 (Multiple EEI’s Permitted per conveyance?)
15 CFR Part 30
“Shipment.” All goods being sent from one USPPI to one consignee located in a single country of destination on a single conveyance and on the same day. Except as noted in §30.2(a)(1)(iv), the EEI shall be filed when the value of the goods is over $2,500 per Schedule B or HTSUSA commodity classification code.

Question: We typically ship multiple container loads of goods on the same vessel which I am interpreting as the “single conveyance” noted in part 30 of 15 CFR. All of the container loads contain cargo value of greater than $2500 which then requires an EEI filing and all cargo is sold from the same USPPI and is destined for the same foreign Consignee/address. For file keeping purposes, it is easier for us to file separate EEI’s for each container rather than only filing 1 EEI for all of the containers moving on the same vessel. Is our current practice of multiple EEI”s per single vessel (conveyance) permissible?

Number 2 (Routed vs. Non-Routed Shipment Definition When Exporting to Company owned Foreign Subsidiary)
FTR section 30.3(e)
(e) Responsibilities of parties in a routed export transaction. The Census Bureau recognizes “routed export transactions” as a subset of export transactions. A routed export transaction is a transaction in which the FPPI authorizes a U.S. agent to facilitate the export of items from the United States and to prepare and file EEI.

Question: We export from our US based company (USPPI) to our foreign-wholely-owned subsidiaries around the world. Does the fact that the FPPI, in this case, our foreign subsidiaries who are the consignees, have any bearing on whether or not the shipment is “routed” vs. “non-routed”? We control the exporting logistics and arrange the bookings, etc.

#37 Comment By Global Reach Daniel On April 10, 2014 @ 1:08 pm

@goodmann33,
To answer you first question, the information you provided suggests that you have ONE shipment so you would only need one ITN for all containers. As for your second question, the fact that the ultimate consignee is your foreign subsidiary does not dictate whether your shipment is routed or not. Routed export transactions occur when the Foreign Principal Party in Interest (FPPI) is controlling the movement of the goods to be exported out the U.S. In other words, the FPPI is selecting a specific carrier who will pick up the items for export and they are also authorizing an agent to complete the AES filing.

#38 Comment By Casimira On September 13, 2014 @ 7:04 am

Helpful information. Lucky me I found your website accidentally, and I’m shocked why this coincidence did not came about in advance! I bookmarked it.

#39 Comment By Hector On October 23, 2014 @ 4:21 pm

If my customer in Thailand has his forwarder here in the US pickup the freight.. Do I mark No or Yes on the S.L.I.? I’m trying to understand this routed export transaction box..

#40 Comment By josefina.hicho On October 23, 2014 @ 5:31 pm

@Hector,
If you are working on behalf of the foreign party and they are controlling the movement of the goods, then yes it is a routed export transaction.

#41 Comment By Jennifer On November 3, 2014 @ 2:34 pm

Who has authority to sign the FPPI POA?

#42 Comment By Adeniyi Adedeji On January 30, 2015 @ 4:23 pm

I am a foreign exporter and I want to hook up with some USPPI, How can I find one?

#43 Comment By Global Reach Stephen On February 9, 2015 @ 7:29 am

@ Adeniyi Adedeji: While we are not able to point you directly to USPPI’s, you might find [5] helpful with the information available there.

#44 Comment By Sarra On April 9, 2015 @ 4:54 pm

Could I please have the answer to Traci question January 16, 2014 at 3:16 pm

Quote – “Is it still considered a routed transaction if the FPPI is providing to us, the USPPI, an account number for the shipper of their choice? This means they are controlling the movement of goods, right?”

#45 Comment By Global Reach Shannon On April 16, 2015 @ 6:41 am

@Sarra: The Foreign Trade Regulations (FTR) defines 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 to prepare and file the EEI.” The type of export transaction is not determined by who is paying for the movement of the goods. If the FPPI authorizes a U.S. agent to facilitate the export of items from the U.S., it is a routed transaction.

#46 Comment By Bret Ulibarri On April 30, 2015 @ 2:45 pm

If the FPPI controls the movement of goods but both the USPPI and FPPI agree on an agent (Freight forwarder) and the USPPI has authorized this agent in writing, is this transaction standard or routed?

#47 Comment By Global Reach Shannon On May 12, 2015 @ 10:47 am

@Bret: The definition of a routed export transaction is a transaction in which the FPPI authorizes a U.S. agent to facilitate export of items from the United States on its behalf and prepare and file the EEI. If the FPPI is controlling the movement of the goods, then they must authorize a party in the U.S. to file on their behalf as they cannot do the filing on their own. As the authorized agent in a routed transaction, you must have a power of attorney or written authorization from the FPPI to be able to file the EEI.

#48 Comment By Bret On May 12, 2015 @ 11:00 am

In the event that the FPPI refuses to authorize the agent, butthe USPPI has already done so, does the transaction type change? What can an agent do in this situation?

I’m getting the sense that “controlling the movement of goods” is a more important criterion than “who is authorizing the agent” in an routed export transaction. The phrase “controlling the movement of goods” is not found in 15 CFR 30.3 however. Please confirm…

#49 Comment By Brian R. On May 27, 2015 @ 12:23 pm

Many of the attempts to explain a routed transaction speak of who controls the movement of the goods. But I haven’t found any satisfactory attempt to define “controls”. I feel our situation is more complicated, and certainly different, from every other one I’ve heard or read described.

We have a strong working relationship with a single foreign consignee, who is not related to us. They order goods that *we* specify, from multiple U.S. sellers, which are consolidated at a warehouse we arrange. We subsequently arrange the exportation of those goods, which are used by the consignee to construct a new product for our mutual clients. There may be other mitigating factors, but that’s the most succinct way I can think to describe our situation.

We have been operating under the belief that we are the USPPI (though we’re not selling the goods). We make the shipping arrangements, and provide the related data elements to the forwarding agent of our choice, who files the EEI (though we may begin doing so in the future). I would contend that we are therefore in control of the movement of the goods.

I would appreciate receiving assistance in determining whether this describes a standard, or routed, export transaction. Thanks!

#50 Comment By Global Reach Shannon On June 11, 2015 @ 7:59 am

@Brian R.: The definition of a routed export transaction is a transaction in which the FPPI authorizes a U.S. agent to facilitate export of items from the United States on its behalf and prepare and file the EEI. If the FPPI is controlling the movement of the goods, then they must authorize a party in the U.S. to file on their behalf as they cannot do the filing on their own. If you have further questions about your specific scenario please contact us at 800-549-0595, Option 3 or e-mail at [6].

#51 Comment By Ritesh On June 16, 2015 @ 8:23 am

The responsibility has been defined broadly as FPPI controls the shipment but does not explain the point on “when” does the FPPI need to authorize his agent to file EEI. For a minute, let us forget about control and talk about responsibility.

It basically depends on who has the responsibility for export clearance. Under terms EXW, the responsibility of export clearance is that of the buyer/consignee (FPPI) and hence they need to authorize an agent to handle the export Customs formalities. Under FCA Works, even though the shipment is picked up from supplier’s door, the responsibility of export clearance is that of the supplier/shipper and they have to arrange for export clearance. Please note that that under both EXW and FCA Works the “control” of the shipment remains with the consignee/buyer, but the export clearance responsibility is that of the buyer under EXW (routed transaction) and that of the seller under FCA Works (standard transaction).

#52 Comment By Global Reach Shannon On June 22, 2015 @ 11:32 am

@Ritesh: The Foreign Trade Regulations (FTR) do not define or use Incoterms such as EXW or FCA Works. Per the FTR, in a routed export transaction, the FPPI will need to authorize an agent to file their EEI, as they are not permitted to file in the Automated Export System (AES) on their own. If the U.S. seller is the USPPI and the U.S. seller is responsible for the movement of the goods, then the FPPI would not authorize an agent as this would be a standard export transaction.


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