June 30, 2022
Guidance on Filing the USPPI Address and State of Origin in the Automated Export System
This broadcast is intended for U.S. Principal Parties in Interest (USPPI) when their USPPI Address State and State of Origin do not match on the Electronic Export Information (EEI) in the Automated Export System (AES). Please review the information below and your internal business practices to ensure EEI filings are compliant with the definitions provided in the Foreign Trade Regulations (FTR). If the U.S. states do not match, begin filing in compliance with the FTR going forward.
The following guidance is consistent with Title 15, Part 30, FTR when reporting the USPPI Address and State of Origin in the EEI in the AES. On March 17, 2020, the Census Bureau released a Global Reach Blog titled USPPI Address: Getting it Right in the Automated Export System. This notice is a reminder to the trade community to report the correct USPPI Address as defined in section 30.6(a)(1)(ii) and the State of Origin in section 30.6(a)(4) of the FTR.
The Census Bureau has researched the reporting of these two data elements in the AES and discovered that over 12 percent of the EEI contained differences even though the definitions are merely identical. As a result, the Census Bureau’s Trade Regulations Branch (TRB) contacted USPPIs whose USPPI Address State and State of Origin did not match to educate and train on the AES filing requirements. The overall goal of this research is to determine if the removal of the State of Origin data element would have any risk to the Census Bureau’s statistical processing.
Below is a common example of how to properly report the USPPI Address and State of Origin data elements:
A U.S. company, Pack, Inc. (Pack), headquartered in Texas sold goods to a foreign buyer in the United Kingdom. The goods originated in several states and were consolidated by a freight forwarder in California to be prepared for export. Pack could not determine the state where the highest value of goods originated. Therefore, to be compliant with the FTR, the USPPI Address and State of Origin shall be California, where the goods were consolidated. This is the case, even if Pack does not own/lease the consolidation facility. Pack would be incorrect if they reported their headquarters in Texas as the USPPI Address and State of Origin because that is not the location where the goods actually began their journey to the port of export.
For reference, the definitions from section 30.6 of the FTR are provided below:
(a)(1)(ii) Address of the USPPI. In all EEI filings, the USPPI shall report the address or location (no post office box number) from which the goods actually begin the journey to the port of export even if the USPPI does not own/lease the facility. For example, the EEI covering goods laden aboard a truck at a warehouse in Georgia for transport to Florida for loading onto a vessel for export to a foreign country shall show the address of the warehouse in Georgia. For shipments with multiple origins, report the address from which the commodity with the greatest value begins its export journey. If such information is not known, report the address in the state where the commodities are consolidated for export.
(a)(4) U.S. state of origin. The U.S. state of origin is the 2-character postal code for the state in which the goods begin their journey to the port of export. For example, a shipment covering goods laden aboard a truck at a warehouse in Georgia for transport to Florida for loading onto a vessel for export to a foreign country shall show Georgia as the state of origin. The U.S. state of origin may be different from the U.S. state where the goods were produced, mined, or grown. For shipments of multi-state origin, reported as a single shipment, report the U.S. state of the commodity with the greatest value. If such information is not known, report the state in which the commodities are consolidated for export.
If additional clarification is needed on this topic or any other regulatory matters, please contact the Census Bureau’s TRB at (800) 549-0595, Option 3, or email us at emd.askregs@census.gov.
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