If you are shipping goods out of the United States, AES filing requirements kick in whenever a single Schedule B commodity code in your shipment exceeds $2,500 in value, or whenever the goods need any federal export license regardless of value. The filing is called Electronic Export Information (EEI), it goes through the Automated Export System via the AESDirect portal on U.S. Customs and Border Protection’s ACE platform, and it has to be accepted before your cargo leaves the country.
When a Filing Is Required
Value is the usual trigger. If all items sharing the same Schedule B classification number in one shipment add up to more than $2,500, EEI is required.1International Trade Administration. Filing Your Export Shipments through the Automated Export System (AES) The threshold applies per code, not per shipment. Three commodities at $1,500 each under different Schedule B numbers do not trigger a filing on value alone; a single code totaling $2,600 does.
Some exports require a filing no matter what they are worth or where they are going:
- Goods needing a license from the Bureau of Industry and Security, the State Department’s Directorate of Defense Trade Controls, the Drug Enforcement Administration, the Nuclear Regulatory Commission, or any other federal agency.
- Items subject to the International Traffic in Arms Regulations, even when licensing is not required.
- Rough diamonds under the Kimberley Process.
- Used self-propelled vehicles as defined by Customs and Border Protection.
The $2,500 exemption does not reach any of these categories.2eCFR. 15 CFR 30.2 – General Requirements for Filing Electronic Export Information
Who Is Responsible for Filing
The filing obligation sits with the U.S. Principal Party in Interest, usually the U.S. seller or manufacturer that benefits from the export. In a routed transaction where the foreign buyer arranges transportation, the USPPI still has to supply the commodity and transaction data to whoever handles the filing.1International Trade Administration. Filing Your Export Shipments through the Automated Export System (AES)
You can hire a freight forwarder or customs broker to submit the filing, but the regulations require written authorization first. Acceptable forms include an export-specific power of attorney, a signed shipper’s letter of instruction for a single shipment, or a blanket shipper’s letter of instruction covering multiple shipments to a particular consignee and destination.3eCFR. 15 CFR 30.3 – Electronic Export Information Filer Requirements A standard import power of attorney will not work; it lacks the export-specific language the regulations require. Even when an agent files, the USPPI remains responsible for the accuracy of the data. Using a forwarder does not shift liability.
Filing Deadlines by Transport Mode
The filing has to be accepted, and the resulting Internal Transaction Number given to the carrier, by a specific cutoff tied to how the goods leave the country:
- Vessel: 24 hours before cargo is loaded onto the ship at the U.S. port.
- Air, including express couriers: 2 hours before the scheduled departure of the aircraft.
- Truck, including express consignment: 1 hour before the truck arrives at the U.S. border.
- Rail: 2 hours before the train arrives at the U.S. border.
Missing a cutoff is itself a violation, separate from any error in the filing’s content.4eCFR. 15 CFR 30.4 – Electronic Export Information Filing Procedures
What Information You Need
The EEI form takes roughly two dozen data fields. Pulling the information together before you open the system saves time. The core elements:
- USPPI identification: your company name, address, and Employer Identification Number. Social Security Numbers cannot be used for AES registration or filing. If you do not have an EIN, apply for one through the IRS before you file.5U.S. Census Bureau. I Do Not Own a Company – How Can I Register for AESDirect?6U.S. Census Bureau. Employer Identification Numbers: Guidance for Exporting Goods From the United States
- Commodity classification: the 10-digit Schedule B or Harmonized Tariff Schedule number for your goods.
- Value: the selling price (or cost, if the goods are not sold) at the U.S. port of export, including inland freight, insurance, and other domestic charges, in U.S. dollars.
- Quantity and weight: total units matching the Schedule B unit of measure, plus shipping weight in kilograms including normal packaging.
- Ultimate consignee: name and address of the foreign party receiving the goods.
- Country of ultimate destination: where the goods will be consumed, processed, stored, or manufactured, not necessarily the first foreign port they touch.
- Transport details: mode of transport, carrier name, carrier identification code, and port of export.
- Related-party indicator: whether the USPPI and the ultimate consignee have 10 percent or more ownership in each other.
The full list of mandatory data elements is set out in the Foreign Trade Regulations.7eCFR. 15 CFR 30.6 – Electronic Export Information Data Elements Accurate commodity classification matters most. Misclassifying goods can draw enforcement action even when every other field is correct.
Submitting the Filing and Getting the ITN
EEI filings go through AESDirect, hosted on the Automated Commercial Environment platform run by U.S. Customs and Border Protection.1International Trade Administration. Filing Your Export Shipments through the Automated Export System (AES) Log into the ACE portal, enter your data into the export filing module, and the system runs an automated check to confirm required fields are populated and correctly formatted.
When the filing is accepted, AES generates an Internal Transaction Number, an alphanumeric code that is your proof of filing. Give that ITN to the exporting carrier before the deadline for your mode of transport. Customs officials check the ITN to verify that EEI has been filed. Without it, the shipment can be held at the dock or the border.
Exemptions and the Legend Requirement
Not every export needs a filing. The most common exemption covers shipments where the value of goods under a single Schedule B number is $2,500 or less, provided the goods do not fall into one of the mandatory filing categories above.8eCFR. 15 CFR 30.37 – Miscellaneous Exemptions
A separate exemption covers most exports destined for Canada, based on data-sharing between the two countries. It does not apply when the goods are merely transiting Canada to a third country or being stored in Canada for eventual shipment elsewhere.9eCFR. 15 CFR 30.36 – Exemption for Shipments Destined to Canada The mandatory filing categories override the Canada exemption too: licensed goods and used self-propelled vehicles headed to Canada still require EEI.2eCFR. 15 CFR 30.2 – General Requirements for Filing Electronic Export Information
Claiming an exemption is not just a matter of skipping the filing. You must annotate the bill of lading, air waybill, or other commercial loading document with an exemption legend citing the specific regulatory provision. A low-value shipment would carry the notation “NOEEI 30.37(a)” on the first page, and the exporting carrier’s outbound manifest must include the same legend.10eCFR. 15 CFR 30.35 – Exemption Legends Without the legend, Customs cannot tell a legitimately exempt shipment from one where the exporter forgot to file.
Corrections, Cancellations, and Split Shipments
Consignees change, dates move, quantities shift. The regulations require you to submit corrections, amendments, or cancellations electronically through AES as soon as you become aware of any error. Failing to correct a known inaccuracy is treated as a separate violation.11eCFR. 15 CFR 30.9 – Transmitting and Correcting Electronic Export Information The correction obligation falls on whichever party filed originally, USPPI or authorized agent. There is no grace period. If a shipment is canceled outright, cancel the AES record rather than leaving a filing that no longer matches an actual export.
When a carrier splits cargo covered by one EEI record across multiple vessels, trucks, or aircraft, you do not need a new filing for the later portions if they leave the same port on the same type of carrier within the allowed window: 24 hours for vessel, or 7 days for air, truck, or rail. Beyond those windows, file a new EEI record and amend the original.12eCFR. 15 CFR 30.28 – Split Shipments
Penalties
Late filings, missing filings, and false filings are penalized differently. A filing that arrives after the deadline but within ten calendar days is treated as late, with a civil penalty of up to $1,100 per day of delinquency, capped at $10,000 per violation. No filing at all, or one more than ten calendar days late, becomes a failure-to-file violation with a civil penalty of up to $10,000 per violation. False or misleading information also carries civil penalties of up to $10,000 per violation.13eCFR. 15 CFR 30.71 – False or Fraudulent Reporting on or Misuse of the Automated Export System These amounts are adjusted annually for inflation.
Criminal penalties reach further. Knowingly failing to file, knowingly submitting false information, or using AES to further illegal activity can result in fines of up to $10,000 per violation and imprisonment of up to five years, or both.14Office of the Law Revision Counsel. 13 USC 305 – Penalties for Unlawful Export Information Activities A conviction can also trigger forfeiture of the goods, any property used in the export, and any proceeds from the transaction.