JIG OPPOSES NEW SED REQUIREMENTS OF PROPOSED EXPORTER DEFINITION
The Joint Industry Group said it opposes changing the way exporters identify themselves on shipper’s export declarations that are filed with the U.S. Census Bureau.
The group made its concerns known this week in a letter to the Commerce Department. JIG said it’s responding to a Federal Register notice, dated April 28, requesting comment on proposed revisions to the shipper’s export declaration and its electronic equivalent, the Automated Export System.
In an attempt to better define exporter, Census wants to revise the “Exporter” box (1A) on the shipper’s export declaration to read “U.S. principal party in interest” and to require this entity to provide its Export Identification Number (EIN) or identification number. The agency says its goal is to collect more accurate export data, particularly on ex-works transactions.
Washington-based JIG, which represents 160 companies with a combined trade revenue of $350 billion annually, says Census’ proposed changes go beyond the agency’s statutory authority to collect export information and that it will increase the data burden the shipping industry.
The group said it also opposes the requirement that the U.S. principal party in interest to disclose its confidential EIN number to an unrelated freight forwarder with which the U.S. principal party in interest has no contractual relationship.
JIG members, such as Caterpillar, DuPont, 3M and Weyerhauser, anticipate spending hundreds of thousands of dollars in computer reprogramming, staff training and record keeping to accommodate these changes.
The group proposes that Census add a new field (or box) to the shipper’s export declaration for the U.S. principal party in interest.
“This suggestion permits the exporter, as the term is commonly understood, to continue to appear on the SED. While the USPPI (U.S. principal party in interest) would provide certain information regarding the product to either the exporter or the exporter’s agent in an EXW (ex-works) thereto,” JIG said.
“Furthermore, it would be apparent to law enforcement officials, carriers and freight forwarders that inquiries should be directed to the exporter appearing in the ‘Exporter’ box, not to the USPPI, who does not have title to the goods or information regarding their export from the United States.”
Census has opposed adding a new box in the shipper’s export declaration for the U.S. principal party in interest because of its obligations under the Paperwork Reduction Act.