EXW, FCA or FOB on an aircraft parts quote: who pays, who carries the risk, who files the export

What the shipping term decides, and what it does not

Incoterms® 2020, published by the International Chamber of Commerce (ICC), are eleven three-letter rules for a sale of goods. Each sets where the seller delivers, who pays which leg, where the risk of loss or damage passes, and who handles export and import clearance. A rule means little without its named place: "FCA" names the mechanism, "FCA" plus a street address or an airport cargo terminal names the point.

Two things a rule does not decide. Ownership: ICC's own training material points out that Incoterms do not deal with the passing of title, which the contract sets, typically on payment. And, for a part leaving the United States, who the exporter is: that comes from US regulations.

On most lines, then, the delivery point is something you have to ask for.

EXW, FCA, FOB and the rest side by side

The table leaves out DPU and the sea rules other than FOB, such as CIF, which ICC likewise limits to port-to-port shipments. The rule texts themselves are ICC's; this is a summary of how they split the work.

EXW: the price stops at the seller's door

Under EXW the seller's job ends when the goods are ready at the named place. ICC's commentary is explicit that the buyer loads them onto the collecting vehicle, at the buyer's cost and risk, and that the buyer handles any export clearance. That is why ICC describes EXW as suited to domestic sales, or trade inside a customs union where there are no export formalities, and strongly encourages traders to consider FCA instead when goods cross a border.

For a buyer abroad, an EXW price means your forwarder collects from the seller's premises and every leg after that is yours. It looks lower than an FCA or CIP price for the same part because less is in it.

FCA: usually the better fit for a part that flies

FCA works for any mode of transport, air included. The seller clears the goods for export and hands them to the carrier or other person you nominate at the named place. If that place is the seller's premises, the seller loads them onto your carrier's vehicle; if it is somewhere else, such as your forwarder's warehouse or an airport cargo terminal, the seller brings them there, ready for unloading. Risk passes at that handover.

FCA leaves you the choice of forwarder, routing and speed, and leaves the seller the export clearance in its own country. Between an EXW and an FCA price for the same part, the difference should be loading, any local trucking to the named place, and export clearance.

FOB on a parts quote usually means something else

Under Incoterms 2020, FOB is a sea rule. ICC says it is to be used only for sea or inland waterway transport, port to port: the seller delivers when the goods are loaded on board the vessel at the named port of shipment, and ICC's own commentary notes that it fits even containerized sea cargo poorly. A spare part sent by air freight or courier never goes on board a vessel, so an Incoterms FOB cannot describe that shipment.

There is a second FOB, and it is American. The Uniform Commercial Code (§ 2-319) says that under F.O.B. the place of shipment, the seller bears the expense and risk of putting the goods into the possession of the carrier, and it applies F.O.B. to any "vessel, car or other vehicle". US government contracts use the same idea: the FAR clause "F.o.b. Origin" has the contractor deliver the shipment to the carrier at the shipping point and makes it responsible for loss or damage occurring before that delivery. "FOB origin" and "FOB shipping point" come from this domestic usage; the Incoterms rules have no such term.

The domestic FOB says nothing about export clearance, which the Incoterms FOB puts on the seller. Some lines in our data read "FOB Ex-Works", two different delivery points at once. Ask which FOB is meant and, for a part that will fly abroad, ask for FCA with a named place.

Who files the US export: the Incoterm does not decide

When the part leaves the United States, the Foreign Trade Regulations (15 CFR part 30) are blunt about it: international commercial terms and terms of sale do not determine the type of export transaction or who the parties to it are, because they have no regulatory basis. EXW on the quote does not remove the US seller from the export.

The US principal party in interest (USPPI) is the person in the United States that receives the primary benefit of the export, generally the seller; the foreign principal party in interest (FPPI) is the buyer abroad. The filing is Electronic Export Information (EEI), submitted through the Automated Export System (AES).

Standard or routed

• Standard: the USPPI files the EEI or authorizes a US agent to. Under FCA and the C and D rules export clearance is the seller's, so the seller normally arranges it.
• Routed: you, the FPPI, authorize a US agent, typically your forwarder, in writing to facilitate the export and file the EEI. You may instead authorize the seller in writing to file; the export is still routed. If an EXW purchase is routed, it is because you gave that written authorization, not because of the letters EXW.
• The seller stays in the picture. In a routed export the seller is still the USPPI and must give your agent complete, accurate and timely export information.
• So does the licensing decision. Under the Export Administration Regulations, the USPPI remains the exporter that determines license authority (license, license exception or NLR) unless you give it a writing in which you expressly assume that responsibility; your US agent then becomes the exporter for EAR purposes, and the seller must, on request, give it the ECCN or enough technical information to classify the item.

How a part is classified, and which destinations and end users change the answer, is covered in our export control guide for aircraft parts buyers.

When EEI is required

The main value exemption: no EEI is needed when the goods under one Schedule B number, from one USPPI to one consignee on one conveyance, are worth $2,500 or less. The test is per Schedule B number, not per shipment. That exemption does not apply, and EEI is filed regardless of value, in the cases listed in 15 CFR 30.2(a)(1)(iv) and 758.1(b). For aircraft parts the ones most likely to matter: a Commerce (BIS) or State Department license is required; the item is subject to the ITAR, even when it is exempt from a license; "600 series" and 9x515 items; destinations in Country Groups E:1 and E:2; a party on BIS's Unverified List; and items on the Commerce Control List going to China (Hong Kong included), Russia or Venezuela (with a narrow exception). The lists are longer than this, so check them, or ask your forwarder, before relying on the exemption.

In a routed export, your forwarder needs the data the EEI carries: the parties' names and addresses, the Schedule B or HTS number, the ECCN where required, description, quantity, value and license authority. On an AOG part that has to fly tonight, ask before you order whether the seller will supply it and when.

CPT, CIP, DAP and DDP in brief

• CPT: the seller books and pays the freight to the named destination, but the risk passes when the goods are handed to the first carrier. Damage in transit is your loss, though the seller paid the freight.
• CIP: CPT plus insurance to the destination. Incoterms 2020 asks for cover at the Institute Cargo Clauses (A), "all risks" level, where CIF asks only for the minimum, Clauses (C).
• DAP: the seller delivers to the named destination, still loaded on the arriving vehicle. Import clearance, duties and taxes are yours.
• DDP: the seller also clears the import and pays the duties. ICC notes that some countries require the local importer to clear the goods; there DDP cannot be used and DAP is the rule to use.

A C or D price includes freight you cannot see; ask which carrier and service level it assumes.

"EXW + city" when the aircraft is on the ground

"EXW" plus a city reads like a location, but a city is not a delivery point. ICC advises naming the place precisely; a vague one invites unexpected transport or storage costs, delays and disputes. For an AOG line, the missing details decide whether the part moves today:

• Whose premises. The seller's warehouse, or stock held by someone else? Your forwarder needs the street address.
• Which country. The named place can be in a different country from the seller's letterhead, with its own export rules and its own flights to you.
• When it is ready. Ask when the part will be ready at the named place, and whether it can be released outside business hours.
• Who loads. Under EXW the seller is not obliged to load your forwarder's vehicle.
• Who files. If the part leaves the US under EXW and your forwarder files, the seller's export data has to reach the forwarder before the flight.

Lead time on a quote usually runs to shipment, not to your door; see aircraft parts lead time and the AOG checklist.

Dangerous goods lines

Some aircraft parts are dangerous goods in transport. Under US hazardous materials rules, whoever offers a hazardous material for transport must classify and describe it and use authorized packaging (49 CFR 173.22). Whatever the term, ask whether the line is dangerous goods, its UN number and class, whether DG packing and paperwork are in the price, and who signs as shipper.

What to ask the seller so two quotes can be compared

Then bring every offer to your door by adding freight, clearance, duties and fees to the offers that stop earlier. For the rest of the offer (condition, certificates, trace, lead time), see why aircraft part prices differ.

If one of the offers on your sheet is ours: MG-AVIATION prices are Ex Works our warehouse in Orlando, FL. Where the supplier states it, each line shows the country the part ships from, and in our client portal the cost of bringing a line to Orlando is shown separately per line ("Shipping / line").

Sources

• FCA & EXW Incoterms® 2020 explained: key differences — ICC Academy, January 2025.
• FCA & FOB Incoterms® 2020 explained: key differences — ICC Academy, November 2024.
• CIF & CIP Incoterms® 2020 explained — ICC Academy, October 2024.
• DAP & DDP Incoterms® 2020 explained: key differences — ICC Academy, February 2025.
• Incoterms® 2020 C rules vs D rules: risk transfer explained — ICC Academy, January 2026.
• Incoterms® 2020: New Rules, Old Problems — ICC Academy, March 2020.
• Understanding the place of delivery and risk transfer in international trade contracts — ICC Academy, July 2025.
• 15 CFR part 30, Foreign Trade Regulations: §§ 30.1, 30.2, 30.3 and 30.37 — eCFR.
• 15 CFR part 758, Export Clearance Requirements: §§ 758.1 and 758.3 — eCFR.
• Freight forwarder guidance and best practices — Bureau of Industry and Security.
• UCC § 2-319, F.O.B. and F.A.S. Terms — Legal Information Institute, Cornell Law School.
• FAR 52.247-29, F.o.b. Origin — Acquisition.gov.
• 49 CFR 173.22, Shipper's responsibility — eCFR.
• Spec 300: Specification for Packaging of Airline Supplies — Airlines for America.