Industry News

BIS Proposes Removal of Routed Export Transaction; Seeks Comments Regarding USPPI and FPPI
February 10, 2014

On February 6, 2014, the Department of Commerce‘s Bureau of Industry and Security (BIS) published a notice in the Federal Register (79 FR 7105) requesting comments on a proposed rule seeking to remove the term “Routed Export Transaction”, and replace it with “Foreign Principal Party Controlled Export Transaction,” in the Export Administration Regulations (EAR).  Additionally, the proposed rule refines procedures for creating a “Foreign Principal Party Controlled Export Transaction.”  By issuing this proposed rule, BIS seeks to enhance clarity of the defined term and to clarify the responsibilities of the U.S. principal party in interest (USPPI) and the foreign principal party in interest (FPPI).

The proposed rule clarifies the transaction process between the U.S. exporter and the foreign buyer.  If the foreign buyer (FPPI) seeks to assume responsibility for transportation of items from the United States to a foreign country, then they must follow specific guidelines outlined in the EAR.  First, the (EAR) requires the “exporter” to be in the United States.  Thus, the FPPI must authorize a U.S. agent to proceed with the transportation of the goods.  According to the proposed BIS rule, the USPPI must consent to the delegation through a written authorization.  Then, the FPPI must accept the delegation in writing and identify the U.S. agent authorized to act as the exporter.  Additionally, the USPPI must provide the FPPI with any information regarding the licensing process, such as the item’s export control classification number (ECCN).

BIS is accepting comments on this proposed rule until April 7, 2014.  Comments can be submitted electronically or in writing.  Online comments may be submitted at or via email to with subject line RIN 0694-AF67.  Written comments can be submitted to Regulatory Policy Division, Bureau of Industry and Security, U.S. Department of Commerce, Room 2099B, 14th Street and Pennsylvania Avenue NW., Washington, DC 20230.

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