It could be loaded on an interim vessel that would be taken to the port, for example, on a through bill of lading. It has already potentially begun its exportation at that point. Or does the legislation intend to capture the moment when the goods move from the intermediate transportation mode to the boat--if it's going by boat?
We don't know exactly when the exportation takes place. Is it when the exporter signs off on the “B13” documentation and hands that over to Customs? It needs to be more precise in terms of what act actually constitutes exportation.
The other point I made was that there is no definition as to who is considered to be the exporter. I think this is relevant in connection with establishing a number of issues, including responsibility for payment of the export tax. It's not as simple in that case as saying, well, it's the person who put it on the boat. My goodness, there are hundreds of people, and maybe several companies, involved in dealing with that.