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Exporter of Record in the USA

The United States exports semiconductors, aircraft, pharmaceuticals, machinery, medical devices, soybeans, and petroleum products to Canada, Mexico, China, Japan, the United Kingdom, and the European Union. Outbound cargo moves through the Port of Los Angeles, Port of Long Beach, and Port of New York/New Jersey for sea freight, and through Los Angeles International Airport (LAX), JFK, and O’Hare International Airport (ORD) for air cargo. To act as the legal exporter of record in the United States, an entity must qualify as a USPPI (U.S. Principal Party in Interest) under 15 CFR Part 30 (Foreign Trade Regulations) and hold a registered EIN (Employer Identification Number) with the IRS. A foreign company without US entity registration cannot qualify as the USPPI and cannot file EEI (Electronic Export Information) through the ACE AESDirect portal. The Bureau of Industry and Security (BIS) administers export licences under the Export Administration Regulations (EAR), while the Directorate of Defense Trade Controls (DDTC) governs ITAR-controlled munitions exports.

Carra Globe acts as your Exporter of Record in the USA, qualifying as the USPPI and holding a registered EIN for EEI filing through ACE AESDirect. Carra Globe manages EEI submission, ECCN classification across the Commerce Control List, BIS export licence applications, DDTC authorisations for ITAR-controlled items, OFAC restricted party screening, USMCA certificates of origin, and Schedule B classification for every shipment. For cargo movement, Carra Globe integrates freight forwarding into every third-party EOR USA solution by sea and air.

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Exporter of Record in the USA

What is an Exporter of Record in the USA

An Exporter of Record in the USA is the USPPI (U.S. Principal Party in Interest), the entity named on the EEI (Electronic Export Information) filed through the Automated Export System (AES) on the ACE AESDirect platform under 15 CFR Part 30 (Foreign Trade Regulations). The US Census Bureau collects EEI data and the Bureau of Customs and Border Protection (CBP) enforces export clearance at US ports of exit. The USPPI carries legal accountability for EEI accuracy, ECCN classification, export licence compliance, and denied party screening on every outbound shipment. A foreign company without US entity registration and a valid EIN cannot qualify as the USPPI and cannot file EEI to AES. Read our guide on what is an Exporter of Record before shipping goods from US territory.

Why Foreign Companies Cannot Export from the USA Without an EOR

The person who files EEI to AES must be physically located in the United States at the time of filing, per 15 CFR 758.1(e). A foreign company without a US entity cannot meet this requirement and cannot transmit EEI through ACE AESDirect. Without a valid ITN (Internal Transaction Number) from AES, carriers cannot load cargo at US ports or airports. Beyond the filing barrier, BIS issues export licences only to US-registered entities under the EAR, meaning a foreign company cannot independently apply for a BIS licence for dual-use goods, controlled semiconductors, or items on the Commerce Control List (CCL). DDTC similarly requires a registered US entity to apply for an ITAR licence for items on the US Munitions List (USML).

What Carra Globe Manages as Your EOR in the USA

  • EEI filing through ACE AESDirect: Carra Globe files the Electronic Export Information as USPPI before cargo departs, providing the ITN to the carrier within the required timeframe
  • ECCN classification: Carra Globe classifies all goods against the Commerce Control List and determines the correct licence authority (licence number, licence exception symbol, or NLR designation) for each EEI line item
  • BIS export licence applications: Carra Globe submits BIS licence applications for dual-use goods, controlled technology, and CCL-listed items requiring BIS authorisation before export
  • DDTC ITAR authorisations: Carra Globe obtains DDTC licences and agreements for ITAR-controlled items on the US Munitions List before shipment to any foreign destination
  • OFAC and denied party screening: Carra Globe screens all consignees against the BIS Entity List, Denied Persons List, Unverified List, and OFAC Specially Designated Nationals list before EEI is filed
  • USMCA certificate of origin: Carra Globe issues USMCA certificates of origin for qualifying goods exported to Canada and Mexico under the US-Mexico-Canada Agreement
  • Schedule B classification: Carra Globe determines the correct Schedule B number for every commodity to ensure accurate EEI reporting to the US Census Bureau
EOR in the USA

Common Export Holds & Fines in the USA: How Carra Globe Protects Your Cargo

The most frequent causes of US export holds follow a consistent pattern: EEI not filed before carrier departure deadline, ITN not provided to carrier before loading, incorrect ECCN on EEI, BIS export licence absent for CCL-listed goods, ITAR-controlled item shipped without DDTC authorisation, consignee on BIS Entity List or OFAC SDN list, Schedule B number misclassified, NLR claimed without ECCN verification. Every one results in cargo held at the port, a BIS or DDTC violation, or both.

Carra Globe prevents these by verifying compliance before cargo departs: classifying every item against the CCL, filing EEI within the required deadline, providing the ITN to the carrier before loading, and completing multi-list restricted party screening before any shipment is accepted.

USA Export Compliance Framework (2026)

Export Declaration System and Customs Authority

The US Census Bureau administers the AES (Automated Export System) under 15 CFR Part 30 (Foreign Trade Regulations). EEI must be filed through the ACE AESDirect portal before departure: no later than 2 hours before scheduled departure for non-ITAR shipments and no later than 8 hours before for ITAR-controlled items. EEI is required for all shipments where the value of a commodity under a single Schedule B number exceeds USD 2,500, or where an export licence is required regardless of value. CBP enforces export compliance at ports of exit. The official AES filing portal is census.gov/foreign-trade. For USA import compliance under CBP, see our Importer of Record in the USA page.

Export Licences and BIS Controls

The Bureau of Industry and Security (BIS) administers the Export Administration Regulations (EAR) under 15 CFR Parts 730 to 774, controlling the export, re-export, and in-country transfer of dual-use goods, software, and technology. Every item exported from the US must be classified against the Commerce Control List (CCL), with classification resulting in an ECCN or an EAR99 designation. Items with an ECCN may require a BIS licence depending on destination, end-user, and end-use. BIS processes standard licence applications within 9 business days for most EAR items, with a 60-day statutory review period for complex applications. The official BIS portal is bis.gov.

ITAR and DDTC Controls

The Directorate of Defense Trade Controls (DDTC), under the US Department of State, administers the International Traffic in Arms Regulations (ITAR) under 22 CFR Parts 120 to 130. ITAR controls the export, temporary import, and brokering of defence articles and defence services on the US Munitions List (USML). Every ITAR-controlled export requires either a DDTC licence, a DDTC agreement, or an applicable exemption under 22 CFR Part 123. Unlike EAR, ITAR carries no de minimis threshold: any foreign-made item incorporating ITAR-controlled US content remains subject to ITAR regardless of the percentage of US-origin content.

OFAC Sanctions and Denied Party Screening

The Office of Foreign Assets Control (OFAC), under the US Department of Treasury, administers US economic sanctions programmes covering Cuba, Iran, North Korea, Russia, Syria, and specific individuals and entities on the Specially Designated Nationals (SDN) list. Exporting goods to an OFAC-sanctioned party or jurisdiction without authorisation constitutes a violation regardless of whether the exporter had actual knowledge of the sanctions status. BIS additionally maintains the Entity List, the Denied Persons List (DPL), and the Unverified List, each requiring separate screening before EEI is filed.

USMCA Certificate of Origin and Trade Agreement Compliance

The US-Mexico-Canada Agreement (USMCA), in force since 1 July 2020, creates preferential duty treatment for qualifying goods exported to Canada and Mexico. USMCA certificates of origin are self-certified by the exporter and carry full legal liability for origin declarations, including applicable Regional Value Content (RVC) thresholds and tariff classification change rules. The United States also maintains bilateral free trade agreements with 17 additional countries including South Korea (KORUS FTA), Singapore, Australia, Chile, and Colombia, each requiring country-specific certificates of origin for preferential tariff claims.

Export Documents Required in USA

  • EEI (Electronic Export Information): filed through ACE AESDirect as USPPI; produces the ITN which must be provided to the carrier before loading
  • Commercial invoice: exporter EIN, full goods description, Schedule B number, declared export value in USD, Incoterms, country of origin
  • Packing list: gross and net weights, dimensions, contents per package
  • Bill of Lading or Airway Bill: must reference the ITN in all material particulars for CBP export manifest compliance
  • Shipper’s Letter of Instruction (SLI): authorises the freight forwarder or customs broker to act as the USPPI’s US agent for EEI filing
  • BIS export licence: CCL-listed dual-use goods, controlled semiconductors, and technology requiring BIS authorisation
  • DDTC licence or agreement: ITAR-controlled defence articles, technical data, and defence services on the USML
  • USMCA certificate of origin: qualifying goods for preferential tariff treatment at Canadian and Mexican ports of entry
  • CITES export permit from USFWS: goods derived from CITES-listed species, issued by the US Fish and Wildlife Service
  • AMS filing (Automated Manifest System): sea freight exports requiring CBP pre-departure manifest filing 24 hours before loading

EOR vs Shipper of Record in the USA: Key Differences

These are two distinct legal roles under US export control law, and companies that confuse the two face BIS or DDTC violation liability.

  • Exporter of Record (USPPI): the US-registered entity legally named on the EEI in AES, carrying full liability for EEI accuracy, ECCN classification, licence compliance, and denied party screening under 15 CFR Part 30 and the EAR
  • Shipper of Record: the party identified on the Bill of Lading or Airway Bill as the physical sender of cargo
  • Who CBP and BIS hold accountable: the USPPI, not the Shipper of Record, for every export compliance obligation
  • Practical application: a foreign company can appear as Shipper of Record while Carra Globe acts as USPPI and EOR, maintaining full legal compliance without requiring US entity registration

For companies importing goods into the United States, see our Importer of Record in the USA page.

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Carra Globe EOR Services in the USA

Carra Globe’s USA EOR service covers the full export compliance chain from origin to border: Exporter of Record, Importer of Record, Delivered Duty Paid, freight forwarding by sea from Los Angeles, Long Beach, and New York/New Jersey and by air from LAX, JFK, and ORD, white glove delivery for high-value defence, aerospace, and medical device shipments, warehouse logistics at bonded facilities near major US export hubs, and global trade compliance covering CCL classification, BIS licence management, and OFAC screening across 175+ countries. Carra Globe’s EOR network extends across key export markets: Philippines, Brazil, Colombia, UK, Taiwan, China, UAE, Mexico and Germany. For USA import compliance, see our Importer of Record in the USA page.
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Frequently Asked Questions: Exporting from the USA

What is a USPPI and how does it differ from an Exporter of Record in the USA?

USPPI stands for U.S. Principal Party in Interest. It is the US legal term for whoever is responsible for the export. That entity files the EEI, holds the export licence, and takes liability for everything that leaves the country. Carra Globe acts as your USPPI on every shipment, so you do not need a US company to do it yourself.

No. You need a US entity and EIN to file EEI in AES, and the filer must be physically in the United States. If you have no US presence, Carra Globe steps in as the USPPI, files everything on your behalf, and carries the legal responsibility. You keep control of your goods without setting up a US subsidiary.

No. The US Constitution prohibits Congress from taxing exports, so there are no general export duties. There is also no VAT in the US, so no zero-rating system applies. The compliance focus is entirely on export licences, ECCN classification, and sanctions screening, not tax.

No, only items with a specific ECCN on the Commerce Control List. Goods classified as EAR99 require no BIS licence for most destinations. The issue is knowing which classification applies to your product. Getting it wrong, even if the goods turn out to be EAR99, is still a filing violation. Carra Globe classifies every shipment before EEI is filed.

AES issues an ITN within minutes of a complete EEI submission. CBP physical inspections at the port take 4 to 24 hours when triggered. BIS licence applications average 9 business days for standard items, up to 60 days for complex reviews. DDTC ITAR licences take 60 to 120 days. The biggest delays come from controlled goods, not the customs process itself.

A routed export happens when the foreign buyer appoints their own US agent to handle the shipment. That agent files the EEI and becomes the USPPI. The problem is the original US seller can still be held liable by BIS if the agent gets it wrong. Carra Globe takes on the USPPI role in routed transactions, removing that liability from the seller completely.

BIS can fine up to USD 364,992 per violation under EAR, with criminal penalties reaching USD 1,000,000 and 20 years imprisonment for wilful cases. DDTC ITAR violations carry civil penalties up to USD 1,478,967 per violation. OFAC sanctions breaches can reach the greater of USD 375,635 or twice the transaction value. These are per-violation figures, meaning a single shipment with multiple items can multiply fast.

Advanced chips and related equipment typically fall under ECCNs 3A090, 3B001, 3E001, or 3D001 depending on performance specs. For controlled items, Carra Globe submits the BIS licence application through SNAP-R with the required end-user documentation. Shipments to China, Russia, and certain other destinations face additional BIS review, adding 30 to 60 days to the standard timeline.

Yes. Carra Globe acts as USPPI for outbound shipments and as IOR for goods entering the United States. If you export from the US and later receive returned units for repair, Carra Globe covers both legs under one provider. EEI filing, BIS licences, CBP entry, and freight all sit in one place.

Yes. Carra Globe manages DDTC licence applications for items on the US Munitions List, prepares the technical data package, and coordinates with the defence end-user for the required end-use statement. ITAR licences take 60 to 120 days so early engagement matters. Carra Globe flags ITAR jurisdiction at the classification stage before a shipping date is confirmed.
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