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Exports Between the United States and Puerto Rico – When to File Electronic Export Information

August 17, 2020
Written by: Edgard Almodóvar-Cotto, U.S. Census Bureau, Economic Management Division, Trade Data Collection Branch, and Jessica Mangubat, U.S. Census Bureau, Economic Management Division, Trade Regulations Branch

Hello trade community! Welcome back for the third and last part of this three-part blog series about export shipments to Puerto Rico. If you have not read the previous parts, please see part 1 and part 2. In this final part, we are going to delve into routed export transactions: reviewing what they are, what roles are involved, and what special options are available to filers since we are effectively dealing with domestic shipments between the United States and Puerto Rico. Although it will be a short entry, routed export transactions between the United States and Puerto Rico are quite common, and you will see why.

Routed Export Transactions Between the United States and Puerto Rico

A routed export transaction is when the Foreign Principal Party in Interest (FPPI), which is generally the buyer located in the foreign country, facilitates the export of the goods from the United States. For example, if the FPPI contracts a U.S. freight forwarder to facilitate the export of the goods out of the United States, then the FPPI is controlling the facilitation of the export of the goods and this is a routed export transaction. (To learn more about routed export transactions, we invite you to read “Clarification Of Routed Export Transactions.”) This definition also applies when a Puerto Rican company is considered the FPPI in a routed export transaction with the United States. Generally, FPPIs are unable to file in the Automated Export System (AES), since only U.S. entities are allowed to file. Therefore, an FPPI must authorize a U.S. agent to file on their behalf.

However, Puerto Rico is a U.S. territory. In this case, unlike other foreign companies, a Puerto Rican company may do the filing. Since the Puerto Rican company itself is the FPPI, it does not require a power of attorney (I mean, why would you need one for yourself?). In the Electronic Export Information (EEI) filing, the “Routed export transaction indicator” must still be marked as “Yes.”

What about transactions in reverse? In part 1 of this series, we explained EEI is also necessary for shipments from Puerto Rico to the United States.

Can a U.S. company or entity file EEI for shipments from Puerto Rico destined to the United States?

Yes.

Can the U.S. company or entity be the FPPI?

If the company or entity is the buyer or end user, then yes, in this special case, the U.S. company or entity can be the FPPI.

So you are saying that the U.S. buyer is the foreign party in these shipments exported from Puerto Rico to the United States?

Yes and no. It may sound strange to consider the U.S. company or entity as the FPPI in this case. However, the U.S. company or entity fulfills the role as the party abroad who purchases the goods for export or to whom final delivery or end-use of the goods will be made, as defined in FTR 30.1. Essentially, the U.S. company or entity is acting as the FPPI in these routed export transactions involving Puerto Rico. Similarly, just like in the cases where a Puerto Rican company or entity is the FPPI and can still file the EEI, the U.S. company or entity can file the EEI when it is the FPPI.

We hope this series helped answer questions you may have about shipments involving the United States and Puerto Rico.

Feel that there is something we missed? Believe there is something to add? Have a topic you want us to cover or have a question? Write or call us! Visit the regulations webpage, e-mail us at <emd.askregs@census.gov>, or call us at 1-800-549-0595, option 3.

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