The Department of Commerce chairs the coordinating committee of federal trade promotion and finance agencies charged with implementing the NEI. CS is one of four business units within Commerce’s International Trade Administration. The other units are Market Access and Compliance, Manufacturing and Services, and Import Administration. CS is the largest unit in terms of budget and staff, and about two-thirds of its staff work at posts outside the United States. CS’s statutory purpose is to promote the export of goods and services from the United States, particularly by small and medium-sized enterprises (SME), and to advance and protect United States business interests abroad. While CS’s mission specifically identifies SMEs, CS assists companies of all sizes. According to the U.S. Census Bureau, in calendar year 2009, the total number of identified U.S. export firms was about 276,000, of which over 97 percent were SMEs. The dollar value of exports associated with the efforts of SMEs that year amounted to about $308 billion, which represented approximately one-third of the $939 billion in exports. CS employs a variety of staff in its global network. Domestically, CS had about 500 staff working in Washington, D.C., and throughout the United States in 2010. Overseas, CS mainly employs Foreign Service officers and locally employed staff. In 2010, CS had over 900 staff overseas, including both Foreign Service officers and locally employed staff.  CS operates 108 domestic offices referred to as U.S. Export Assistance Centers. Staffed by trade specialists, and Foreign Service officers on domestic tours, the centers deliver the full range of export promotion services to U.S. companies and connect to CS’s global network of overseas offices. The centers work cooperatively with key partner agencies and organizations, especially the Export-Import Bank, the Small Business Administration, and state trade offices. (See app. II for the allocation of domestic CS staff in fiscal year 2010, by state.)  CS’s 125 offices in more than 75 countries promote U.S. exports and defend U.S. commercial interests, implementing the full range of Department of Commerce overseas commercial services. Foreign Service officers, referred to as commercial officers, manage the overseas offices and engage in activities requiring a U.S. official. Locally engaged staff, consisting of commercial specialists and commercial assistants, provide export promotion services to U.S. companies and support the commercial officers in other activities. (See app. III for a table of country groupings and allocation of overseas CS staff in fiscal year 2010.) In 45 countries where the CS has no presence, it engages in a Partnership Program with the State Department (State) under which State Foreign Service officers and locally employed staff provide some export promotion assistance. In September 2011, the Departments of Commerce and State agreed to expand the program to an additional 11 countries. The formal Partnership Program began in January 2009; however, CS and State have a long history of working together because, for many years, commercial officers were part of State until the Commercial Service was established as a separate entity under Commerce in 1980. (See app. IV for the locations of State Department partnership posts providing export promotion services.)  CS also operates a Trade Information Center, which serves as a central point of contact for U.S. exporters seeking export advice such as how to begin exporting; complying with trade documentation requirements, standards, and regulations; and accessing other U.S. government trade programs and resources. Additionally, CS’s Advocacy Center, in Washington, D.C., with support from CS offices abroad, assists individual firms in various industry sectors competing for foreign government contracts. The goals and activities of the U.S. and Foreign Commercial Service contribute to the National Export Initiative (NEI) goal of doubling the dollar value of U.S. exports from $1.57 trillion in 2009 to $3.14 trillion by the end of 2014. CS’s strategic goals include expanding the exports of U.S. goods and services, removing obstacles to exporting, particularly for small and medium-sized companies, and advancing U.S. business interests abroad by advocating on their behalf and helping to remove foreign trade barriers. CS conducts a variety of activities to advance these goals, generally falling into four broad categories: (1) trade counseling, (2) fee-for-service activities, (3) commercial diplomacy, and (4) advocacy. In addition to these core activities, CS assists other U.S. agencies overseas involved in trade- related activities, mainly at overseas posts. Our interviews with Foreign Service officers and locally employed staff at the six posts we visited indicate that counseling and fee-for-service activities are the primary focus of their day-to-day activities and take most of their time. However, CS also promotes the export success of U.S. firms and advances U.S. business interests abroad by helping firms overcome obstacles in specific markets through commercial diplomacy and by advocating on their behalf for foreign government contracts. When any CS trade-promotion activity successfully assists a U.S. company to export a product or service, CS staff document an “export success” that is verified by CS management. An export success is defined as a CS service, rendered by locally employed staff, Foreign Service officers, or U.S. Export Assistance Centers, that facilitates (1) a sale of a product or service; (2) a commercial agreement (distribution, wholesale, or joint venture); or (3) an overseas activity resulting in revenue for a U.S. company or its affiliate or subsidiary. Trade counseling involves assisting U.S. businesses in understanding foreign markets and developing export marketing plans, as well as providing information about export finance and public and private export promotion assistance. CS counsels thousands of firms each year, particularly SMEs. CS counsels firms that have never exported, as well as firms already exporting that want to expand their efforts to one or more new markets or to increase their exports to one or more markets where they already have a presence. (CS categorizes these types of firms, respectively, as new-to-export, new-to-market, and increase-to-market.) From 2008 through 2010, according to CS, it had approximately 68,000 clients, and counseling activities were the primary service provided in over 18,000 export successes during that period. CS’s fee-for-service activities include standardized services such as matchmaking, which CS generally refers to as a Gold Key—introducing U.S. businesses to qualified buyers overseas—and providing market intelligence such as reports on a specific foreign company, which CS refers to as International Company Profiles. CS also provides customized services such as Business Facilitation Services, Single Company Promotions, Customized Market Research, Trade Missions, and Webinars, among others. CS is authorized to charge a user fee for its export promotion services. Since May 2008, its standardized fees have been based on full-cost recovery for large companies and a lower amount for new-to-export SMEs. Fees for customized services also vary based on company size, with large companies paying more than SMEs. Large companies pay 100 percent of both direct and indirect costs, whereas SMEs pay 100 percent of direct costs but 35 percent of indirect costs. From fiscal year 2008 through 2010, U.S. firms purchased a total of 27,076 services from CS, of which approximately 68 percent were purchased by SMEs. CS collected approximately $19 million in fees for these services. CS addresses a wide variety of obstacles that U.S. companies may face in specific markets by conducting commercial diplomacy on their behalf, as well as by assisting with formal efforts by the International Trade Administration’s Market Access and Compliance unit to remove government-imposed barriers such as standards or technical barriers and subsidies. Overall, from fiscal year 2008 through 2010, CS successfully assisted 486 companies through commercial diplomacy efforts, resulting in at least $17 billion in exports. Commercial diplomacy occurs when CS’s interactions with foreign governments contribute to achieve one or more of the following outcomes: reduce, eliminate, or prevent a foreign trade barrier; comply with a bilateral or multilateral trade agreement;  eliminate or reduce a threat to U.S. business interests; and create market opportunities. For example, if a company comes to CS indicating that a shipment of mackerel valued at $100,000 is being held by customs in a particular European country due to a regulation that is inconsistent with its international trade obligations, CS may assist the company by engaging the foreign government to advocate that the regulation—in this case requiring a European Union health certificate—is inconsistent with a bilateral trade agreement. If CS’s diplomacy efforts are successful in this case, the European Union member would rescind the regulation and release the shipment from customs. CS could then count this case as a commercial diplomacy success. CS also assists Market Access and Compliance led teams in overcoming existing or potential trade barriers facing U.S. companies or exporters. Because of their overseas presence, CS commercial officers on these teams generally represent U.S. interests in interactions with foreign governments. In addition, these teams may work to ensure that U.S. exporters receive benefits of a trade agreement or avoid potential inconsistencies in the implementation of an agreement. For example, CS, in collaboration with Market Access and Compliance, might help a U.S. firm that is stymied by a country’s arbitrary customs valuations that would lead to excessive tariffs on the firm’s products. The Market Access and Compliance team, with CS playing a key role, would advocate on behalf of such a company in a concerted effort to get the country to honor its commitments under the World Trade Organization’s Customs Valuation Agreement. From fiscal year 2008 through 2010, Market Access and Compliance initiated 664 such cases and reported that it successfully resolved 248 cases with CS assistance.