Choosing the Ultimate Consignee Type

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By: Heather Hrytsyshyn

You probably know that identifying the ultimate consignee in the Automated Export System (AES) is mandatory. However, did you realize that you need to select an ultimate consignee type? There are four types: direct consumer, government entity, reseller and other/unknown.

Let’s dive into the details of each type: woman questioning

  1. Direct Consumer is a non-government institution, enterprise, or company that will consume or use the exported good as a consumable, for its own internal processes, as an input to the production of another good or as machinery or equipment that is part of a manufacturing process or a provision of services and will not resell or distribute the good.
  2. Government Entity is a government-owned or government-controlled agency, institution, enterprise, or company.
  3. Reseller is a non-government reseller, retailer, wholesaler, distributor, distribution center or trading company.
  4. Other/Unknown is an entity that is not a Direct Consumer, Government Entity or Reseller, as defined above, or whose ultimate consignee type is not known at the time of export.

Helpful tips to consider:

  • If the form of the good (commodity) exported is changed or consumed by the ultimate consignee, the type would be direct consumer.
  • If you chose other/unknown and later determine the ultimate consignee type changed, you may update the type in the AES.

So which type do you choose?

Identifying the proper ultimate consignee is pretty simple. Just remember to focus on the primary business function of the ultimate consignee. If more than one type applies, choose the type that applies most often. Let’s take a look at a couple of examples:

Example 1: If you export printers to a company in Scotland and they use the printers in their office, what ultimate consignee type do you choose?

Drum roll please… Direct Consumer.

The Reason: The ultimate consignee is using the printer for its own consumption.

Example 2: If you export paintings to an art distributor in France, what ultimate consignee type do you choose?

Drum roll please…Reseller

The Reason: The ultimate consignee is a distributor.

For more information on ultimate consignee type, refer to Section 30.6(a)(28) in the Foreign Trade Regulations. If you still have questions, contact the Regulations, Outreach and Education Branch at 1-800-549-0595, Option #3.

woman questioning

 

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26 Responses to Choosing the Ultimate Consignee Type

  1. Jenny says:

    What if you are selling to a sales office? The shipment is delivered to a Laredo Broker for consolidation and then delivered to the sales branch or the end user in Mexico. We have the end user information, but it is a routed shipment. Sometimes it is gets shipped to the sales office for a short period of time prior to going to the end user. Who would be listed as the ultimate consignee on the AES?

    • Global Reach Daniel says:

      @Jenny,
      The Ultimate Consignee is the person or party abroad that actually receives the goods. Based on the information you provided, the ultimate consignee is the party in Mexico that receives the goods.

  2. Julia says:

    Informative and well describe explanation. Excellent!

  3. Mohamad Abujawayed says:

    Government Entity is a government-owned or government-controlled agency, institution, enterprise, or company.
    Is there a minimum percentage of ownership by the government for a company to be considered a government entity?

    • Global Reach Daniel says:

      @Mohamad,
      Government ownership must be 100% to be considered Government Entity.

      • Rebecca says:

        At Update, it was stated that government funded agencies/entities were “government”. I asked about civilian agencies such as NASA (page states that they are a civilian agency) and other Research labs that are funded both by private funds and govt funds and was told to call them government. What about public universities that are direct consumers but also receive federal funding? Can you please clearly define “government”? Thanks!

        • Heather says:

          @Rebecca- Provide the business function of the ultimate consignee that most often applies for the public universities. Government ownership must be 100% to be considered a Government Entity.

  4. Nova West says:

    When will this field be added to AESPCLink?

    • Global Reach Daniel says:

      @Nova,
      The field is currently “optional” in AESPCLink until the 180 compliance period ends on October 2, 2014.

  5. Cricket says:

    What if you are sending knit componemt parts to be finished then returned? Since the ultimate consignee is finishing the knit component part as opposed to using it up, and they are returning it, is it really a direct consumer?

  6. Heather says:

    @Cricket, if the form of the good is changed, this would still be a direct consumer.

  7. Lanie says:

    What if you are sending parts to the Ultimate Consignee to be repaired or to be exchanged and they are returning it. Would the type be considered Direct Consumer, Other/Unknown, or Reseller?

  8. Rooster says:

    If I’m selling an aircraft part to a company that repairs planes for an end user, (commercial or military) how would you classify my customer?
    Thanks for your help.

  9. John says:

    We have a large export program with lots of consignees most of which fall to reseller. There is, however, a sizeable representation of consumer and government entities and then some that fall to both consumer and reseller. Our challenge? We don’t have a way of tracking the ultimate consignee types in our system and reporting this to our forwarder. Would it be acceptable to default to #4 unknown?

    • Heather says:

      @John, if you know the type of consignee, then that should be reported at the time of export. I would suggest finding a way to fix your system so the correct information can be reported.

  10. Cricket says:

    We own plants in both the USA and Honduras. We knit in the USA then send to Honduras to finish. They send back to us in the USA and we ship to our customers. When we ship the Knit Component Parts to Honduras, they are not a reseller or the goverment. Please confirm if OTHER is the correct one for me to use. Would using OTHER on so many shipments raise a concern? Or since we ship to them as knit component parts (6117.90.0000) and they are returned to us as a finished product with a different HTS then maybe I should use DIRECT CONSUMER?

  11. Cricket says:

    I am sorry. I see that my question was answered before and I missed it.

  12. Cherril says:

    I just want to confirm, we manufacture aircraft parts and sell the parts to the aircraft manufacturers (i.e. Airbus, Bombardier, etc.). From what I’m understanding, because they use our product when manufacturing aircraft they are direct consumer. Can you please provide concurrence that I’m interpreting it correctly. Thank you.

  13. Mike says:

    We have been getting requests from forwarders for us to include the ultimate consignee type on our SLI for routed export transactions. In reading 15 CFR 30.6, it makes the most sense that the forwarder will need to ask the FPPI what the ultimate consignee type is. As an exporter we typically do know the end user, but this may be different than the ultimate consignee. It may be important to note that we do make the licensing determination. Can you provide clarification on this?

  14. Mike says:

    Who is responsible for providing the ultimate consignee type in a routed export transaction? The USPPI or the FPPI?

    Thanks!

  15. Heather says:

    @Mike, if the FPPI authorizes a U.S. agent to file on his or her behalf, then the authorized agent is responsible for providing the ultimate consignee type in the AES. If the FPPI authorizes the USPPI to file on his or her behalf, then the USPPI is responsible for providing the ultimate consignee type in the AES.

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