Certificate to Foreign Government (CFG) - who is an Exporter ?

SGquality

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#1
In the Form 3613 for Certificate to Foreign Government (CFG), Page 4 has to be filled by an Exporter. I wanted to know who is the Exporter in the below case -

we are a contract manufacturer and our establishment has been also registered with FDA as "Contract Manufacturer". Now, the Specification developer and our customer wants us to fill this page 4 as an exporter ... I have aksed for clarification as we are not responsible for distribution, recall and related activities and hence we as a contract manufacturer should not be filling this page.

Am I correct in my understanding ? Pls help me !

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#3
our customer wants us to fill this page 4 as an exporter
we are not responsible for distribution
I don't see a regulatory issue. The party that ships devices out of USA is the exporter. If you do that shipping, you're the exporter. If you provide the devices to some other party and they ship them out of USA, they're the exporter.

It sounds to me though as if you have a business-relationship disagreement with your customer.

How does your business work with regard to non-exported product? Do you ship directly to customers or dealers? Or do you ship only in bulk to the Specification Provider or to a third party as directed by the Specification Provider, and that other party ships to the customers or dealers?
 
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