The traffic manager for a U.S. exporter sent in the following question about new export regulations, (JoC Week, July 24-30):

QUESTION: A U.S.-based manufacturer sells to a U.S. company, f.o.b. plant. The second U.S. company sells to a third U.S. company, f.o.b. plant. The third company sells to a foreign entity, in China. Who is the U.S. principal party in interest (the party with responsibilities for export compliance)? The originator? The intermediate, or the direct seller to the foreign entity?

ANSWER: The third U.S. company that sold to the foreign entity in China. The first two sales were domestic transactions. (Answer provided by Census Bureau's foreign trade division.)


Regarding the report, ''Advice for Importers,'' (JoC Week, July 24-31) there are many things importers can do to manage their liability resulting from the Customs Mod Act and Informed Compliance. None of these steps are exclusive of the others. There is no be-all, end-all solution. And while I generally agree with Rob Pisani's advice of hiring an expert, simply seeking the services of an attorney, or other professional, may not be enough in and of itself.After all, importers have been buying the services of brokerage companies and law firms for years.

In my experience, in both Customs brokerage and import compliance for an importer, outside parties cannot possibly understand the complexities of products and transactions as well as the importer can. Only by being in the thick of it on a day-to-day basis can one uncover many of the ''gotchas'' that would spell trouble in a Customs audit. Of course, most importers don't have the talent on staff to recognize problems when they see them. And by the time an im-porter has paid an outside professional for this round-the-clock presence, he might as well have made him an em-ployee - which is entirely my point. At the risk of sounding self-serving myself, the single best way an importer can have this talent is to employ it.

As a licensed customs broker, for many years, I brought my expertise to an importer, and closed the knowledge gap that so often exists between importers and regulators. The need for the customs broker and the customs attorney still exist - None of these steps will exclude the others. But in the end, the broker's work is more accurate, the legal expenses are kept down and, most of all, Customs is satisfied.

Jim Dickeson