The U.S. Census Bureau has announced significant updates to the Foreign Trade Regulations (FTR), affecting definitions, filing responsibilities, and reporting procedures for exporters.

The U.S. Census Bureau has introduced a series of amendments to the Foreign Trade Regulations (FTR), aiming to bring greater clarity to definitions, responsibilities, and filing procedures. These changes, effective in 2025, impact a wide range of businesses engaged in international trade. While some updates formalise existing practices, others create new obligations that exporters and their partners must prepare for.

Key changes to FTR definitions

Several definitions under FTR 30.1(c) have been revised, with implications for how parties are identified in the export process. Updates include:

• Revised terms: Buyer, End User, Filer, Foreign Port of Unlading, Foreign Principal Party in Interest (FPPI), Forwarding Agent, Intermediate Consignee, Order Party, Seller, Shipment, Ultimate Consignee, and U.S. Principal Party in Interest (USPPI).
• Addition: Conveyance.
• Removal: Consignee.

These updates are designed to provide clearer guidance on the roles and responsibilities of each party in the export transaction. For exporters, this means paying closer attention to how supply chain partners are identified within filings, as misalignment could increase compliance risk.

Filing requirements and exclusions

The FTR clarifies mandatory filing requirements, including those related to Drug Enforcement Administration (DEA) exports. In addition, the regulation reinforces that goods transiting through the U.S., Puerto Rico, or the U.S. Virgin Islands, without entering for consumption or warehousing — remain excluded from Electronic Export Information (EEI) filing.

Businesses using the U.S. as a transit hub should note that these rules confirm existing exclusions but also tighten scrutiny on goods incorrectly declared as transit shipments.

General filer requirements

Section 30.3 has been revised to stress that:

• The filer must be a USPPI or an authorised agent.
• The filer must be physically located in the U.S. when filing EEI.
• EEI must be filed completely, accurately, and on time.

Importantly, the rules make clear that Incoterms or other contractual terms do not determine the parties to an export transaction.

This distinction is critical for exporters relying on complex contract structures. Businesses can no longer assume that commercial terms align with regulatory responsibilities.

USPPI scenarios

A number of updates clarify responsibilities for the U.S. Principal Party in Interest (USPPI):

• Foreign entities: If a foreign entity is physically in the U.S. when goods are purchased and moved for export, they will be listed as the USPPI in the EEI but cannot file directly. An authorised U.S. agent must be appointed.
• Previously imported goods: If goods are re-exported within 30 days of import without change or enhancement, the customs broker that is listed as importer of record must be the USPPI. After 30 days, responsibility shifts to the warehouse or storage facility in possession of the goods.
• Foreign Trade Zones (FTZs): If a U.S. person admits goods into an FTZ, they are listed as USPPI when exported. If a foreign person admits goods, the FTZ operator assumes this role.

For companies operating across multiple jurisdictions or using FTZs, these updates introduce added complexity, making it essential to establish clear operational ownership early in the export process.

AES downtime policy

A new section [30.4(f)] defines the Automated Export System (AES) Downtime Policy. If AES is unavailable, exporters must:

• Provide the correct downtime citation.
• File the EEI at the earliest opportunity once the system is restored.
• Exports requiring mandatory EEI filing cannot proceed until AES is operational and an Internal Transaction Number (ITN) is issued.

This effectively means that planned shipments may be delayed during downtime, increasing the importance of proactive scheduling and contingency planning.

Data element updates

Changes to data reporting include:

• Address of Origin: Formerly the “USPPI Address,” this field continues to require the U.S. location where goods begin their journey to the port of export.
• Ultimate Consignee: Expanded scenarios now clarify whether the consignee is the end user or a reseller/distributor.
• Entry Number: Must be reported when foreign-origin goods enter the U.S. for warehousing or are admitted into an FTZ.

These updates reflect the Census Bureau’s increased focus on visibility and traceability of supply chains. Exporters should expect closer scrutiny of how goods flow through different U.S. entry and exit points.

Other notable updates

• Disclosure of EEI to foreign persons remains prohibited.
• Repair values must now include inland/domestic freight, insurance, and related charges.
• AES use in furtherance of illegal activity may result in account deactivation in addition to existing penalties.
• Voluntary Self-Disclosure (VSD) rules have been updated to exclude filings from foreign persons or their representatives.
• A new Appendix C specifies the responsibilities of USPPI and authorised agents in routed export transactions.

Together, these adjustments show regulators’ intention to close gaps in filing practices, emphasising accountability at every stage of the export process.

What this means for businesses

These updates are designed to improve the accuracy, consistency, and compliance of U.S. export filings. While many changes clarify existing practice, others place greater responsibility on exporters and their agents to correctly identify roles and ensure filings are complete.

For UK and European companies trading with the U.S., the impact will be felt most in compliance oversight and supply chain coordination. Getting it wrong could mean shipment delays, financial penalties, or increased regulatory scrutiny.

Now is the time to review your U.S. export processes, audit responsibilities across your supply chain, and ensure that EEI filings are robust and accurate. Woodland Group can support you with compliance audits, training for teams, and hands-on management of export filings to safeguard your business against disruption.

For tailored advice and support with your U.S. export processes, please contact your Woodland Group representative.