There's a reason for this.
Decades ago, the U.S. Census Bureau amended the FTR and replaced the term exporter with U.S. Principal Party in Interest, commonly referred to as the USPPI. While the change was intended to bring clarity and consistency to export reporting, it has had the opposite effect for many businesses.
Understanding who the USPPI is—and why it matters—remains one of the most misunderstood aspects of U.S. export reporting. That confusion often surfaces when companies are trying to determine who is responsible for filing electronic export information (EEI) through the Automated Export System (AES), particularly in routed export transactions.
This article explains what the USPPI is, why the definition exists and how to determine the USPPI in real-world scenarios using practical case studies. It also reflects current Census Bureau guidance and the 2025 amendments to the Foreign Trade Regulations, which clarified several long-standing points of confusion.
The Census Bureau revised the FTR for several related reasons:
First, to clearly define which party benefits most from an export transaction, rather than relying on informal or inconsistent use of the word exporter.
Second, to specify who is responsible for providing key data elements used in U.S. export statistics and enforcement, regardless of who physically files the EEI.
Third, to create consistency in export reporting, particularly when multiple parties are involved, such as freight forwarders, agents and foreign buyers.
For purposes of EEI filing, the FTR makes one thing explicit:
The exporter reported to AES is always the USPPI.
That does not mean the USPPI always files the EEI. It does mean the USPPI is the party whose identity anchors the AES record and whose data must be reported accurately.
According to the Census Bureau, the USPPI is:
The person in the United States that receives the primary benefit, monetary or otherwise, of the export transaction.
In most cases, the USPPI is easy to identify. It is often the U.S. seller, manufacturer or distributor that sold the goods to a foreign customer.
However, the FTR also recognizes that a foreign entity can be the USPPI if that entity is physically present in the United States when the goods are purchased or obtained for export. This clarification was reinforced in the 2025 FTR amendments and related Census guidance.
What matters most is not who arranged transportation or who filed paperwork, but who benefits from the transaction itself.
The FTR is equally clear about who generally cannot be listed as the USPPI.
A freight forwarder or consolidator cannot be the USPPI simply because they arranged transportation or filed EEI. Their role is logistical, not transactional.
There is one narrow exception:
A freight forwarder that previously acted as a customs broker to import goods into the United States may be listed as the USPPI only if those goods are exported without change or enhancement. Outside of that specific scenario, forwarders are not the USPPI.
In most export transactions, the USPPI will be one of the following:
Each of these situations has practical implications for EEI filing and data responsibility, which is why we've included some case studies below to highlight those responsibilities.
Identifying the correct USPPI isn't just a paperwork exercise.
Even if your company does not sell directly to foreign customers, you may supply goods to domestic customers who export them. In those situations, you still have compliance responsibilities—particularly if you know, or have reason to believe, that your products will be exported.
In addition, regardless of whether you are the USPPI, you can be held liable if your goods are exported to a prohibited destination or to a denied or restricted party. Export compliance obligations do not disappear simply because someone else handling the EEI filing.
Seller:
Monterrey Fish Supply & Trading Co., Monterrey, California
Monterrey Fish sold 30 metric tons of frozen fish to a customer in Taiwan under Incoterms 2020 Rule CIP, Kaohsiung, Taiwan, with international freight prepaid.
Monterrey Fish appears as the shipper on the international bill of lading and issues the commercial invoice.
USPPI: Monterrey Fish Supply & Trading Co.
Exporter reported to AES: Monterrey Fish Supply & Trading Co.
Why this matters:
This is a classic example where the USPPI and the exporter are the same party. Monterrey Fish made the international sale, benefits from the transaction and controls the export process. There is little ambiguity.
Seller:
Monterrey Fish Supply & Trading Co., Monterrey, California
Supplier:
John’s Fishing Co., Brainerd, Minnesota
John’s Fishing sold frozen fish to Monterrey Fish under Incoterms 2020 Rule EXW, Brainerd, Minnesota. Monterrey Fish arranged international transportation and paid all transportation charges.
Monterrey Fish appears as the shipper on the ocean bill of lading and issues the international commercial invoice.
USPPI: Monterrey Fish Supply & Trading Co.
Exporter reported to AES: Monterrey Fish Supply & Trading Co.
Why this matters:
Although John’s Fishing is part of an international transaction, it is not the USPPI. Monterrey Fish made the international sale and receives the primary benefit. This distinction often surprises domestic suppliers who assume they are the exporter simply because their goods left the country.
Many exporters use Incoterms such as Ex Works (EXW), where the foreign buyer selects the freight forwarder. Under the FTR, this is known as a routed export transaction.
A routed export transaction does not change who the USPPI is. It changes who is authorized to file the EEI. In this type of transaction, the FTR requires the Foreign Principal Party in Interest (FPPI)—typically the buyer—to authorize a party in the U.S. to submit the EEI filing.
This distinction is critical and frequently misunderstood.
Seller:
John’s Fishing Co., Brainerd, Minnesota
John’s Fishing sold frozen fish to a buyer in Hong Kong under Incoterms 2020 Rule EXW, Brainerd, Minnesota. The buyer’s freight forwarder arranged transportation and billed charges to the consignee.
Payment is made under a letter of credit requiring John’s Fishing to appear as the shipper on the bill of lading.
USPPI: John’s Fishing Co.
Exporter reported to AES: John’s Fishing Co.
Why this matters:
Even though the buyer selected the freight forwarder, John’s Fishing made the international sale and benefits from the transaction making them the USPPI. The routed nature of the shipment impacts who can do the EEI filing.
If goods are imported into the United States and placed into a Foreign Trade Zone (FTZ) or bonded warehouse before being exported without processing, the 2025 FTR amendments clarify that the party in possession of the goods may be designated as the USPPI, depending on the facts of the transaction.
Why this matters:
Older guidance led many companies to assume the original importer was always the USPPI. Census has clarified that transactional benefit and control, not historical ownership, determine USPPI status in certain in-transit and FTZ scenarios.
Companies should carefully review these situations and may need to consult with the Census Bureau or a knowledgeable compliance professional to fully understand the requirements.
When a shipment is routed, the FPPI must authorize a U.S.-based agent to file the EEI through AES. An FPPI will typically authorize a third party like their freight forwarder to handle the filing. Even if the USPPI is not doing the filing, the FTR requires them to provide specific data elements to the filing party. They typically use a shipper's letter of instruction (SLI) to provide that data.
This information includes:
Incoterms define commercial responsibilities between buyers and sellers. They do not determine regulatory obligations under the FTR.
This Census Bureau has repeatedly emphasized this distinction in their informal communications and presentations, but it was recently reinforced with the 2025 amendments to the FTR. Using EXW or CIP does not change who the USPPI is, nor does it transfer compliance responsibility away from that party.
Shipping Solutions hosted a one-hour webinar with staff from the U.S. Census Bureau to discuss the 2025 Foreign Trade Regulation changes and answer exporter questions.
You can:
Both resources expand on the concepts discussed here and provide additional clarity on USPPI responsibilities under the updated rules.
Determining the USPPI in your export transactions isn’t about labels or paperwork. It’s about understanding who benefits from the transaction and who is responsible for ensuring accurate export reporting.
Getting it right protects your company, improves compliance and avoids costly misunderstandings—especially as Census continues to refine and clarify export reporting expectations.
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This post is based on blog posts published in 2001-2002 and written by Catherine J. Petersen. We have updated it many times since then as the U.S. Foreign Trade Regulations and U.S. Census Bureau guidance have been amended.