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Fax in your completed certificates to Worthington Aviation at 651-393-3310

End Consignee Statement / End-Use Certificate (ECS-EUC)

Worthington Aviations’ Global Trade Compliance Program consists of a comprehensive “due diligence/reasonable care” initiative that meets and exceeds the U.S. Export Administration Regulations (EAR Part 744) to “know your end user and the end use of your product”. The End Consignee Statement-End Use Certificate (ECS-EUC) form has been developed in conjunction with 3 leading global trade legal firms to ensure that it fulfills this requirement.

This document is an acknowledgement between Worthington Aviation and their customer that neither will knowingly enter into a transaction that is not sanctioned by trade compliance regulations. It is viewed as a positive tool in the determination of the risk assessment of an exporter/importer.

1 - What is “Reasonable Care”?

Global Trade Compliance is the process by which goods enter the United States in conformance with all U.S. laws and regulations. While trade compliance is a core business process for Customs, a significant amount of the burden of compliance is placed upon importers/exporters. The failure of an importer of record or exporter to exercise reasonable care can delay release of the merchandise and, in some cases, result in the imposition of penalties for acting without reasonable care.

2- What is the purpose of an End Consignee Statement-End Use Certificate?

The ECS-EUC is a document acknowledging the commitment of both parties to a transaction for due diligence/reasonable care by:

• Providing assurance that the goods will not be used for chemical, biological or nuclear weapons, or for missiles capable of delivering such weapons of mass destruction
• Providing assurance that the goods will not be exported/re-exported to countries that are subject to embargoes and/or trade sanctions without an appropriate license.
• Providing assurance the both parties to the transaction are aware of trade compliance regulatory requirements of all countries with controls over the products involved.
• Providing assurance that both parties are committed to the ideals of safe and secure trade.

3 – Why should I follow U.S. regulations if I only do business outside of the U.S.?

The United States is the only country with extraterritorial re-export controls. They regulate the sales transaction of parts even when they are sold between countries outside of the U.S.

U.S. export/re-export regulations apply when:

• The product is made in the U.S.
• The product is foreign made but travels through the U.S.
• The product is developed from U.S. technology
• The product is sold by a U.S. citizen anywhere in the world
• The product is made by a U.S. company anywhere in the world

It is important to note that some countries, such as Canada, have even signed trade ententes to support in part the U.S. regulations.

4 – Why should I sign the End Consignee Statement-End Use Certificate?

For global security reasons, the U.S. Government requires all companies to know the end destination and end use of all products being sold.

This program is beneficial to everyone by ensuring that Worthington Aviation is considered a low risk importer/exporter. In the case of heightened security, Worthington Aviation is making every effort to ensure that inventory will still be delivered cross-border to all customers. By signing the ECS-EUC, you demonstrate your awareness of your obligation to follow U.S. regulations and may be considered by Worthington Aviation as a low risk partner in a safe and secure supply chain.

5 – I don’t export. Why should I sign the End Consignee Statement-End Use Certificate?

Due to recent cases of controlled products sold within the U.S. and then illegally diverted to restricted countries, Worthington Aviation has expanded the ECS-EUC program to include domestic as well as export customers. This comprehensive program has been applauded by leaders in the trade compliance environment as a demonstration of the strong commitment to safe and secure trade made by Worthington Aviation and its customers.

6 – Is Worthington Aviation the only distributor/manufacturer requiring the customer to sign an End Consignee Statement-End Use Certificate type of document?

No, Worthington Aviation is not the only distributor/manufacturer that has this type of due diligence/reasonable care program. However, there is no limit to the different formats for these documents or for the situations in which they would be required. Each company determines what will best meet the requirements in their particular business environment..

7 – What is the customer’s liability when signing the End Consignee Statement-End Use Certificate?

The ECS-EUC is not a legal document. It is a positive acknowledgement between business partners demonstrating a commitment to a secure supply chain worldwide.

8 - Where does the reasonable care/due diligence liability end?

The ECS-EUC statement only has an impact on the next level of the supply chain (i.e Worthington Aviation and Worthington’s customer). Worthington Aviation requires confirmation by their customer that they have an awareness of their regulatory responsibilities and that they have no “knowledge” (as defined in the EAR) that the product sold to them by Worthington will be going to a wrong end-user and/or end-use.

9 – By signing the End Consignee Statement-End Use Certificate, is Worthington Aviation passing liability to the customer?

No. Worthington Aviation follows U.S. due diligence recommendations so that it can continue to be considered a low risk distributor. An objective of the ECS-EUC program is to raise customer awareness to help secure the supply chain. All Worthington Aviations’ customers already have the obligation to follow U.S. regulations. The ECS-EUC simply demonstrates our customers’ awareness of this obligation. In signing the ECS, the customer becomes part of our secured supply chain.