If you are shipping goods out of the United States, the Automated Export System filing requirements apply whenever a single commodity in your shipment is valued above $2,500 under one Schedule B number, or when the shipment requires an export license from any federal agency. The filing, called Electronic Export Information (EEI), goes through the Automated Commercial Environment (ACE) portal run by U.S. Customs and Border Protection, and the data is shared with the Census Bureau for trade statistics and security screening.1U.S. Census Bureau. Frequently Asked Questions of the Foreign Trade Regulations (FTR)
When You Have to File
The Foreign Trade Regulations at 15 CFR Part 30 set out the triggers. Value is the most common one: any single commodity classified under one Schedule B number that exceeds $2,500 requires a filing. The threshold applies per commodity classification, not per shipment. A shipment carrying three different products worth $2,000 each does not cross the line; a single product worth $2,501 does.1U.S. Census Bureau. Frequently Asked Questions of the Foreign Trade Regulations (FTR)
Value is not the only trigger. You must file, whatever the dollar amount, if the shipment needs an export license from any federal agency, if the goods are controlled under the International Traffic in Arms Regulations at 22 CFR Parts 120 through 130, or if the destination is a country in Country Group E:1 or E:2.2eCFR. 15 CFR 30.2 – General Requirements for Filing Electronic Export Information (EEI)3eCFR. Supplement No. 1 to Part 740 – Country Groups4eCFR. 15 CFR 30.16 – Export Administration Regulations
When You Don’t
Several exemptions exist. When one applies, you put an exemption legend on the shipping documents in place of the Internal Transaction Number so the carrier and CBP can confirm the shipment is legitimately exempt.
- Low-value shipments under NOEEI 30.37(a): a commodity valued at $2,500 or less per Schedule B classification, provided no license is required and the goods are not ITAR-controlled.
- Shipments to Canada under NOEEI 30.36: exports where Canada is the final destination. This exemption does not apply if the goods are transiting Canada to a third country, being stored there for later shipment elsewhere, requiring an export license, or headed to a Country Group E:1 or E:2 nation.5eCFR. Exemption for Shipments Destined to Canada
- Returned temporary imports under NOEEI 30.37(r): goods previously brought into the U.S. under a temporary import bond that leave in the same condition they arrived.
- U.S. Armed Services shipments under NOEEI 30.39: cargo shipped exclusively for military use.
No exemption applies if the shipment needs a license from any government agency, involves ITAR-controlled items, is destined for a Country Group E:1 or E:2 country, falls under an Office of Foreign Assets Control sanctions program, or contains rough or uncut diamonds.6United States Census Bureau. Filing Citations and Exemption Legends
What You Need Before You File
Gather the core data before touching the system. Bad data is the most common cause of filings coming back as fatal errors.
The Parties
Every filing identifies the U.S. Principal Party in Interest, the person or company that receives the primary economic benefit from the export. The USPPI is identified by its Employer Identification Number. Social Security Numbers are not accepted. If a company has multiple EINs, it reports the one used for employee wages and withholdings rather than the one used solely for company earnings.7eCFR. 15 CFR 30.6 – Electronic Export Information Data Elements
You also identify the ultimate consignee, meaning the person or entity that will actually receive the goods in the foreign country. Accurate names and physical addresses for both parties are required.
Classification and Value
Every product needs a ten-digit Schedule B or Harmonized Tariff Schedule code. The Census Bureau publishes free lookup tools. Misclassification can trigger penalties or hold up the shipment, so this step deserves care on products that sit near the boundary between two codes.
The reported value is not just the sale price. It includes the selling price (or cost, if the goods are not sold) plus domestic freight, insurance, and other charges to get the goods to the U.S. port of export. Sell for $10,000 and pay $250 in domestic freight and insurance, and you report $10,250.1U.S. Census Bureau. Frequently Asked Questions of the Foreign Trade Regulations (FTR)
Shipment Details
You also enter the country of ultimate destination, the U.S. port of export, the quantity and unit of measure for each commodity, and the mode of transport. For vessel and air shipments, the vessel name or flight number lets CBP match the filing to the actual departure.
Submitting Through ACE
All EEI filings go through the ACE portal. Before you can file, you need an account. Check first whether your company already has one. A customs broker or freight forwarder may have already linked your EIN to their account. If you are not sure, contact ACE support at ACE.Support@cbp.dhs.gov.8U.S. Customs and Border Protection. Applying for an ACE Secure Data Portal Account
To apply, you designate a Trade Account Owner, who does not have to be the company’s actual owner, and complete the exporter application through CBP’s website. Once approved, the Trade Account Owner receives login credentials by email. Registration is not instant, so plan ahead.
Inside ACE, you enter the data described above. On a clean submission, the system issues an Internal Transaction Number, which is your proof of filing. You provide the ITN to the carrier before the goods depart. If the system finds missing or conflicting data, it returns a fatal error and no ITN. The shipment cannot legally leave until you fix the problem and resubmit. Common fatal errors involve mismatched country codes, invalid Schedule B numbers, and missing party identification. Fix them quickly, because your filing deadline keeps running regardless of how many attempts it takes.
Filing Deadlines by Transport Mode
The clock runs backward from departure, and the deadline depends on how the goods are leaving. Miss it and the carrier cannot legally load the cargo. For non-ITAR shipments:
- Ocean vessel: at least 24 hours before cargo is loaded at the U.S. port.
- Air cargo: at least 2 hours before scheduled aircraft departure.
- Truck: at least 1 hour before the truck arrives at the U.S. border.
- Rail: at least 2 hours before the train reaches the U.S. border.
- Mail and all other modes: at least 2 hours before exportation.
- Used self-propelled vehicles: at least 72 hours before export.
The ITN, or the applicable exemption legend, has to be in the carrier’s hands before departure. For shipments sent through the U.S. Postal Service, you file and receive your ITN before dropping off the package, and the ITN goes on the customs declaration form.10United States Postal Service. Publication 699 – Special Requirements for Shipping Internationally
Who Is Responsible
The USPPI carries primary legal responsibility for the accuracy of every filing, even when someone else handles the keyboard. Most exporters hire a freight forwarder to do the actual submission, granting authority through a Power of Attorney or written authorization.11Bureau of Industry and Security. Freight Forwarder Guidance and Best Practices Delegating the task does not shift legal liability. If the forwarder files bad data because the exporter supplied bad product descriptions or inflated values, both parties can face penalties.
Every party to the export transaction, meaning the USPPI, any authorized agent, and the carrier, must retain records related to the shipment for five years from the date of export.12eCFR. 15 CFR 30.10 – Retention of Export Information and the Authority to Require Production of Documents Census Bureau records requests three years after a shipment are not unusual.
In a routed export transaction, the foreign buyer (the Foreign Principal Party in Interest) arranges the export logistics and designates a U.S.-based agent to file the EEI. The USPPI’s obligations shrink but do not vanish. You still provide the agent with complete and accurate export information and keep your own documentation to support the data you handed over. In a routed transaction, you do not need to grant a Power of Attorney.13eCFR. 15 CFR 30.3 – Electronic Export Information Filer Requirements, Parties to Export Transactions, and Responsibilities of Parties to Export Transactions
What Noncompliance Costs
Civil penalties break down by violation type:
- Failure to file: up to $10,000 per violation.
- Late filing: up to $1,100 per day overdue, capped at $10,000 per violation.
- Filing false or misleading information: up to $10,000 per violation.
Criminal penalties are steeper. Knowingly filing false export information or knowingly failing to file can bring fines up to $10,000 per violation, imprisonment for up to five years, or both.15Office of the Law Revision Counsel. 13 USC 305 – Penalties for Noncompliance For violations involving export-controlled items, the Bureau of Industry and Security can also deny a company’s export privileges entirely, which effectively shuts it out of international trade.16eCFR. 15 CFR 766.25 – Administrative Action Denying Export Privileges For a pattern of sloppy filings, the penalties can dwarf what the goods themselves were worth.