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Reporting Conventions for Exports of Natural Gas Via Pipeline

Friday, August 22, 2014
Sandler, Travis & Rosenberg Trade Report

The Census Bureau issued Aug. 18 Foreign Trade Regulations Letter No. 9 setting forth reporting conventions for exports of natural gas via pipeline. These conventions were a collaborative effort between Census, U.S. Customs and Border Protection and the pipeline industry and were developed to address some common reporting concerns.

Census states that all U.S. principal parties in interest or authorized agents are expected to fully report all electronic export information for natural gas exports via pipeline, as detailed below, in the Automated Export System. In addition, the pipeline operator must deliver the proof of filing citation, exemption or exclusion legends to the CBP port director within four calendar days following the end of the month.

- state where the natural gas leaves the United States

- nearest CBP port to the actual border crossing location that is valid for a fixed mode of transportation

- date of export: (1) shipments may be filed throughout the month, in which case the date of export should be reported as the actual date of export; or (2) shipments made throughout a given month may be consolidated and reported as one shipment within four calendars days of the end of the month, in which case the date of export should be reported as the last calendar date of that month (consolidated shipments must be shipped from the same U.S. PPI to the same ultimate consignee within the same departure month and through the same pipeline)

- shipments leaving from a foreign-trade zone will be reported the same as all other shipments, but the USPPI or its authorized agent must report the FTZ in AES (shipments originating from various FTZs will need to be filed as separate shipments)

- the ultimate consignee – i.e., the person, party or designee that is located in Canada and actually receives the export shipment (may be the end user or the foreign PPI) – or, if not known, the name and address of the hub in Canada closest to the border crossing

- the quantity in cubic meters

- value, reported using (1) FTR definition (i.e., selling price in U.S. dollars plus inland or domestic freight, insurance and other charges to the land border port of export) or (2) gas daily average pricing (using GDA point closest to where the natural gas crosses the border into Canada)

- USPPI; i.e., the person or legal entity in the U.S. that receives the primary benefit, monetary or otherwise, from the export transaction (generally the U.S. seller, manufacturer or order party, or the foreign entity while in the U.S. when purchasing or obtaining the goods for export)

- USPPI address information

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