Exporter of Record
Also known as: EOR, Principal Party in Interest, USPPI
Definition
The exporter of record (EOR) is the party legally responsible for an international shipment leaving a country. In the United States, this party is called the U.S. Principal Party in Interest (USPPI). The EOR ensures compliance with export regulations and files required documentation.
EOR Responsibilities
Regulatory Compliance
- Determine if export license required
- Screen against denied party lists
- Comply with export control regulations
- File Electronic Export Information (EEI)
- Maintain export records
Documentation
- Commercial invoice preparation
- Shipper’s Letter of Instruction
- AES/EEI filing (when required)
- Export license applications
- Certificate of origin
Who Is the EOR?
Determining EOR (US USPPI)
| Scenario | EOR/USPPI |
|---|---|
| US company sells to foreign buyer | US seller |
| Foreign buyer purchases in US | Foreign buyer (or US agent) |
| US company ships to own foreign subsidiary | US parent company |
| Drop ship from US supplier | Party responsible for export |
General Rule
The EOR is the party that:
- Has the authority to determine if goods will leave the country
- Benefits most directly from the export transaction
EOR Requirements by Country
United States
- USPPI must be in US or authorized agent
- EIN or SSN required
- AES filing for shipments >$2,500
- BIS compliance for controlled goods
European Union
- EU established entity
- EORI number required
- Export declaration filing
- Dual-use goods regulations
Other Countries
- Requirements vary
- Often the selling party
- May need export registration
- Specific documentation requirements
EEI/AES Filing Requirements
When Filing Required (US)
- Shipments valued over $2,500
- Shipments requiring export license
- Certain commodities regardless of value
- Certain destinations
What’s Filed
- Shipper information
- Consignee details
- Commodity description
- Value and quantity
- Transportation details
Exemptions
- Most shipments to Canada
- Shipments under $2,500 (most commodities)
- Personal effects
- Diplomatic pouches
EOR vs. Freight Forwarder
| EOR | Freight Forwarder |
|---|---|
| Legal responsibility | Agent/service provider |
| Files documentation or authorizes agent | Files on behalf of EOR |
| Bears export compliance risk | Acts under EOR’s authority |
| Named on export documents | May prepare documents |
Important: Freight forwarders can file AES as agents but don’t assume EOR responsibility.
Export Compliance Considerations
Denied Party Screening
- Check all parties against restricted lists
- SDN List (OFAC)
- Entity List (BIS)
- Denied Persons List
- Unverified List
Export Controls
- EAR (Export Administration Regulations)
- ITAR (International Traffic in Arms)
- OFAC sanctions
- Determine ECCN classification
Documentation Retention
- Keep records 5 years
- Export declarations
- Licenses and applications
- Correspondence
- Screening documentation
Penalties for Non-Compliance
Civil Penalties
- Up to $300,000 per violation (BIS)
- Up to $1,000,000+ (OFAC)
- Denial of export privileges
Criminal Penalties
- Fines up to $1,000,000
- Imprisonment up to 20 years
- For willful violations
EOR Services
When Needed
- Company lacks export compliance expertise
- Occasional exports not worth building capability
- Complex controlled goods
- Multiple country requirements
Provider Types
- Customs brokers with export services
- Freight forwarders
- Trade compliance consultants
- Specialized EOR companies
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