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Final Rules for International Trade Data Highlight Issues for Routed Export Transaction

(Robert A. Shapiro – Thompson Coburn LLP)

The International Trade Data System (ITDS) is intended to create a single window for reporting international trade activities to all government agencies that may have regulatory authority over a transaction. The Bureau of the Census (Census) finalized its August 22, 2014 interim rules for implementing ITDS with respect to Electronic Export Information (EEI) and for authorizing relevant government agencies to have access to this data. 80 Fed. Reg. 6900 (February 9, 2015).

The sharing of information between government agencies is not necessarily news, but the Federal Register Notice publishing the Interim Final Rule, 79 Fed. Reg. 49659, provides some interesting insight into the impact that ITDS is likely to have on the exportation of goods from the United States. […]

The Final Rule paves the way for the U.S. Principle Party in Interest (USPPI) (generally the seller) to receive EEI through its ACE portal, thus vastly facilitating the ability of the USPPI to implement effective compliance programs. The Census rules, however, limit the EEI data that may be released to the USPPI in a Routed Export Transaction (RET). Click here to read more.