Freight forwarder obligations

Yes. Even though your customer is directing the U.S. forwarder to ship the items, you are not relieved of your obligations. The responsibility for determining the proper export authorization and obtaining an export license, if necessary, is your obligation unless your customer provides you something in writing indicating that they are assigning the licensing responsibility to another party in the United States, such as the forwarder. However, even when this occurs, you will still be listed as the “Exporter” on the AES record and on the export declaration as the U.S. Principal Party in Interest (USPPI). If your customer provides you with a written document verifying that they are assigning licensing responsibility to another U.S. person, you will need to provide specific information to the U.S. person in order for them to take the necessary steps to ensure compliance.