February 20, 2001


FTSR Letter No. 174	
                                                                                                           
To:		U.S. Customs Service Headquarters, Directors of Field Operations, Port Directors, 
Foreign Trade Zone Operators, Department of Commerce District Offices, 
Exporters (U.S. Principal Parties in Interest), Freight Forwarders, Exporting 
Carriers, Consolidators, U.S. Customs Brokers, and All Others Concerned

From:		U.S. Census Bureau (Census Bureau) 

Subject:	Reporting Requirements and Clarification of U.S. Principal Party In Interest 
(USPPI) for Merchandise Imported into the United States for Export to a Third 
Country of Ultimate Destination


This is to clarify requirements for filing a Shipper's Export Declaration (SED) or Automated 
Export System (AES) record for merchandise imported into the United States from a foreign 
country for export to a third country of ultimate destination.  In situations where merchandise is 
being shipped through the United States for export to a third country of ultimate destination, but 
is first entered for consumption or for warehouse in the United States, a SED or AES record must 
be filed when the merchandise is exported out of the United States.  

Only a U.S. entity can be designated as the U.S. Principal Party In Interest (USPPI) on the SED 
or AES record.  Usually, this will be the U.S. importer of record shown on the Customs Form 
7501 entry summary.  By law the importer of record is the owner or purchaser of the imported 
merchandise, or a licensed U.S. Customs broker appointed by the owner, purchaser, or consignee 
of the merchandise.  However, there may be instances when the importer of record on the 
Customs Form 7501 is a foreign entity.  In this situation, the USPPI will be the U.S. resident 
agent designated by the foreign importer for service of process.  In such cases, the USPPI on the 
SED or AES record will not match the importer of record listed on the entry summary.  

The USPPI is thereby responsible for following the provisions for the USPPI as specified in the 
Foreign Trade Statistics Regulations, Title 15, CFR, Part 30, Sections 30.4 and 30.7.  The USPPI, in 
this circumstance, is required to provide the import entry number on the SED or AES record. 

Every effort must be made by all parties in these transactions to comply with the provisions 
contained in the Foreign Trade Statistics Regulations, Title 15, Code of Federal Regulations,
Part 30.  If you have any questions concerning these requirements, please contact the 
Regulations, Outreach, and Education Branch, Foreign Trade Division, on 301-457-2238.



(Signed:   C. Harvey Monk, Jr.)           		
C. HARVEY MONK, JR.
Chief, Foreign Trade Division