U.S. Census Proposes Adding Country of Origin to Export Filings

Trade Update • December 17, 2021

‘Foreign Goods’ Defined

For purposes of the Foreign Trade Regulations “foreign goods” are products that were originally grown, produced, or manufactured in a foreign country, then subsequently entered into the United States, admitted to a U.S. Foreign Trade Zone, or entered into a CBP bonded warehouse, but not substantially transformed in form or condition by further processing or manufacturing in the U.S. (including FTZs), Puerto Rico, or the U.S. Virgin Islands.

Why Is Origin Being Added?

The Bureau says the additional information is needed to improve the trade statistics that it produces and, as part of a broader whole-of-government initiative, to identify the gaps in domestic product and supply, evaluate supply chains, and address trade imbalances.

Obtaining the country of origin for reexports would eliminate the Bureau’s current reliance on foreign partners to provide this data, which it says will “increase the accuracy and timeliness of the foreign trade statistics used to monitor trade agreements and policy to assist in assessing U.S. supply chain issues.”

How Will Exporters be Impacted?

According to the Bureau, there were 33.7 million export records in 2020, of which nearly 1 in 4 (7.9 million records) had exports reported with a Foreign origin indicator.

The Bureau says it “understands that the addition of country of origin for reexports may have implications for the trade” and estimates that it will take 12-18 months to update internal and/or proprietary computer systems, and/or the technology they utilize to implement the required changes to the AES.

For example, your accounting and commercial invoicing system may need to be updated in order to meet the new requirement that each line in the Electronic Export Information indicated as foreign, must show the actual foreign country of origin and be tallied for purposes of calculating the total value of domestic and foreign portions.

Have Your Say

The Bureau is seeking public comments from data users, businesses, and others to assess this proposed data collection change. Questions to consider include:

• How long would it take to make needed software changes to add the country of origin field to your company’s interface to AES?
• Are there business practices that you would need to implement in order to come into compliance with the additional reporting of origin?
• How would the country of origin be identified when you store or warehouse goods of multiple origins together?

Additional suggested questions are provided in the Notice of Proposed Rulemaking.

Comments will be accepted until February 14, 2022, and should be submitted via the Federal eRulemaking Portal (Identification number RIN 0607-AA59).