Compliance
Exporter of Record (EOR) Services
The Exporter of Record (EOR) is the party legally responsible for a U.S. export: for the accuracy of the Electronic Export Information filing, for holding the correct export authorization, and for compliance with ITAR or EAR. Under U.S. export law the EOR is normally the U.S. Principal Party in Interest, but a foreign buyer purchasing on ex-works terms, known as a routed transaction, may appoint a U.S. agent to act as EOR. Forward Systems Group provides Exporter of Record services under its DDTC registration.
How Forward Systems Group runs exporter of record (eor)
Export liability follows the filing, not the money. Whoever is named Exporter of Record owns the penalty exposure if the classification is wrong or the end user turns out to be restricted. It makes no difference who profited from the sale. FSG acts as EOR under its own DDTC registration, and that is only worth anything if the registrant can genuinely carry the obligation.
- 1
Establish the structure
Standard or routed transaction? A foreign buyer arranging transport from a U.S. supplier's dock changes who files, and the supplier's obligations do not end at the door unless the routing is documented.
- 2
Paper the appointment
Written authorization from the foreign principal party in interest, power of attorney and EOR appointment executed before the cargo moves.
- 3
Carry the diligence
Classification, licence determination, restricted and denied party screening, and end-use and end-user statements performed under our registration rather than taken on trust.
- 4
File and retain
AES/EEI filed in our name as EOR, with five-year record retention against the possibility of an audit long after delivery.
FSG is DDTC-registered under M28606, with a working compliance program and the records to evidence it. Those are the three things an Exporter of Record has to have in fact, not just on paper.
Why the EOR question matters
Export liability does not follow the money; it follows the filing. Whoever is named Exporter of Record owns the penalty exposure if the classification is wrong, the license does not cover the shipment, or the end user is on a restricted list. Who profited from the sale makes no difference.
This becomes acute in routed export transactions, where a foreign buyer arranges its own transport from a U.S. supplier's dock. The supplier often assumes its responsibility ends at the door. It does not, unless the routing has been documented properly and the EOR role formally transferred.
- Establishing whether the transaction is standard or routed
- Written authorization from the FPPI appointing the U.S. agent
- Power of attorney and EOR appointment documentation
- Classification, licensing, and restricted party screening under the EOR's own registration
- AES / EEI filing in the EOR's name
- Five-year record retention
When to appoint a third-party EOR
Three situations account for most third-party EOR appointments: a foreign buyer with no U.S. legal presence that needs a U.S. party to file; a U.S. supplier unwilling to take export liability on a sale it treats as domestic; and a program where the exporting entity is not DDTC registered and the cargo is USML-controlled.
In each case the EOR has to be able to carry the obligation in fact, not just on paper. That means current registration, a working compliance program, and the records to prove both.
Exporter of Record (EOR): frequently asked questions
What is an Exporter of Record?
The Exporter of Record is the party legally responsible for a U.S. export: filing accurate Electronic Export Information, holding the required license or exemption, screening the parties, and retaining records for five years. It is normally the U.S. Principal Party in Interest, but in a routed export transaction a foreign buyer may appoint a U.S. agent to serve as EOR.
What is a routed export transaction?
A routed export transaction is one where the foreign buyer, known as the Foreign Principal Party in Interest, takes responsibility for arranging transport out of the United States and authorizes a U.S. agent to facilitate the export. The authorization must be in writing, and it shifts specific filing responsibilities from the U.S. supplier to the appointed agent.
Can Forward Systems Group act as Exporter of Record?
Yes. Forward Systems Group provides Exporter of Record services under its DDTC registration, including for foreign buyers without a U.S. legal presence and for USML-controlled cargo where the supplier is not itself registered.
Need this confirmed against your contract?
Send us your clause list, DD Form 254, or licence position and we will confirm scope against your specific requirement before you commit to a shipment.