@Jack, In a routed transaction, both must occur. The FPPI must facilitate the export and then authorize the USPPI or a U.S. agent to file the EEI. If the FPPI has not authorized a filer, however, that does not mean it is not a routed transaction.
It is just a proof of insurance. Additional Insured: The main contractor is named as an additional insured on the certificate of insurance and is actually given coverage, and has rights under the sub-contractors or vendor's, the Named Insured policy in the event of a future claim.
If the client still insists that it be named an additional insured on you policy, you might work with your. attorney, insurance agent and insurance underwriter to develop alternate contractual language that. would better achieve the clients objectives and be acceptable to the insurer.