DOES A FOREIGN FIRM (BUYER) NEED TO IDENTIFY AS AN FPPI WHEN DEALING WITH A U.S. (SELLER) IN A ROUTED TRANSACTION WHEN THERE IS NO ACTUAL SELLING OF THE EQUIPMENT, BUT THE EQUIPMENT IS LEASED FOR A LIMITED AMOUNT OF TIME (LESS THAN 6 MONTHS) AND THEN RETURNED TO THE U.S.?
The foreign firm (buyer) must identify both a U.S. Principal Party in Interest (USPPI) and a Foreign Principal Party in Interest (FPPI) on the Electronic Export Information (EEI) form if the equipment exported from the U.S. requires an export license for shipment.
If an export license is not required, then an EEI is not necessary as the shipment falls under the Federal Trade Regulation 30.37 (q) exemption, “except as noted in § 30.2(a)(1)(iv), filing EEI is not required for the following kinds of shipments. However, the Census Bureau has the authority to periodically require the reporting of shipments that are normally exempt from filing. Temporary exports, except those that require licensing, whether shipped or hand carried, (e.g., carnet) that are exported from and returned to the United States in less than one year (12 months) from the date of export.”
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