Census Clarifies Ultimate Consignee for Certain Transactions
The U.S. Census Bureau clarified who the ultimate consignee would be for certain scenarios, in a blog post on Sept. 7. The blog post includes a few scenarios wherein the Foreign Principal Party in Interest (FPPI) or foreign buyer is listed as the ultimate consignee, and two of those wherein "reseller/distributor" is listed as the Ultimate Consignee Type if they are reselling or distributing the goods.
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Under the Foreign Trade Regulations, the ultimate consignee is defined as the "person, party, or designee that is located abroad and actually receives the export shipment," the blog post said. The party may be the "end user" or the FPPI, that part of the regulations said.
The regulations also say the filer must report who the Ultimate Consignee is "at the time of export," the blog post said. If the shipment requires an export license, the Ultimate Consignee reported in the Automated Export System is the person designated on the "export license or authorized to be the Ultimate Consignee under the applicable license exemption" or an "exception in conformance" with Export Administration Regulations or International Traffic in Arms Regulations, the blog post said.
The first and "most common" scenario is when the U.S. Principal Party in Interest (USPPI)/U.S. seller has one FPPI/foreign buyer. The FPPI is the only company receiving the goods, therefore the FPPI is the ultimate consignee, the blog post said.
The second scenario is when the USPPI knows the FPPI is going to redistribute or sell those goods to other customers. The FPPI may not report who their customers are, even when the USPPI asks for those customers. Since the only knowledge of where the goods are going is the FPPI, they would be reported as the ultimate consignee and reseller/distributor is filed as the "Ultimate Consignee Type," the blog post said.
The third and final scenario the blog post brought up was when the FPPI discloses the country where the goods will end up to the USPPI, but not the customers. This is again a scenario wherein the USPPI would report the FPPI as the ultimate consignee, reseller/distributor as the ultimate consignee type and the known country of the end user as the "Country of Ultimate Destination," the blog post said.