Electronic Export Information (EEI) Filing: Rules and Deadlines

Electronic Export Information filing requirements apply to almost every physical shipment leaving the United States: if the goods under any single Schedule B classification are worth more than $2,500, or if the shipment needs any federal export license regardless of value, you must file EEI through the Automated Export System (AES) before the carrier can legally move the cargo. The filing produces an Internal Transaction Number (ITN) that goes to the carrier as proof of clearance. Getting it wrong carries civil penalties up to $10,000 per violation and, for knowing violations, up to five years in prison.

When You Have to File

The Foreign Trade Regulations in Title 15 of the Code of Federal Regulations require EEI for all physical goods exported from the United States, Puerto Rico, U.S. Foreign Trade Zones, and the U.S. Virgin Islands, unless a specific exemption applies.¹ The most common trigger is value. Once the goods shipped from one party to one consignee on a single carrier exceed $2,500 under any individual Schedule B number, filing is mandatory.²

Value is not the only trigger. Some shipments require EEI at any dollar amount:

Goods needing a Bureau of Industry and Security (BIS) export license
Items controlled under the International Traffic in Arms Regulations (ITAR)
Exports requiring a Drug Enforcement Administration permit
Shipments needing a Nuclear Regulatory Commission license
Any other goods requiring a federal export license
Rough diamonds
Used self-propelled vehicles

If any of those categories apply, skip the value math and file.¹

When You Don’t Have to File

The regulations carve out a long list of exemptions. The ones most exporters rely on:

Low-value shipments under $2,500 per Schedule B number from one party to one consignee on a single carrier, unless the goods fall into a category that requires filing regardless of value.
Exports where Canada is the final destination. This exemption disappears if goods are only being stored in Canada before moving onward, or if Canada is just a transit point to a third country.³
Temporary exports, such as goods moving under a carnet, as long as no license is required.
Personal effects and baggage of people leaving the United States, including crew, when not shipped as cargo under a bill of lading or air waybill.
Diplomatic pouches and their contents.
Tools of trade: usual and reasonable quantities of equipment and software that a company or its employees carry abroad for business use.
Intercompany documents, invoices, and correspondence shipped from a U.S. firm to its foreign subsidiary or affiliate.

Additional exemptions cover carrier stores, dunnage, books and maps sent to foreign libraries or government institutions, humanitarian gift parcels under License Exception GFT, and airline parts under License Exception AVS.² Even when an exemption applies, you still have to give the carrier an exemption legend in place of a filing citation.

Who Files and Who Is Liable

The U.S. Principal Party in Interest (USPPI) carries primary responsibility. That’s the person or company in the United States receiving the main benefit from the export transaction. The USPPI either files the EEI directly or authorizes an agent, typically a freight forwarder, to file on its behalf.¹

Delegating to an agent requires a power of attorney or other written authorization spelling out each party’s responsibilities and confirming the agent’s authority to create and file EEI. Handing off the keystrokes does not hand off accountability. The filer is responsible for the truth, accuracy, and completeness of the EEI, except to the extent it can show reasonable reliance on information furnished by other parties to the transaction.⁴ The USPPI stays on the hook for accurate commodity descriptions, classifications, and license determinations regardless of who presses submit.

Routed Export Transactions

A routed export transaction flips the usual arrangement. The foreign buyer (the Foreign Principal Party in Interest, or FPPI) controls the export logistics and authorizes a U.S.-based agent to prepare and file the EEI. This is common when the foreign buyer arranges its own shipping.⁴

You don’t get to walk away. As USPPI in a routed transaction, you still have to hand the FPPI’s authorized agent the export data needed to file, including classification numbers, quantity, value, and country of destination. You must also keep documentation proving you provided that data. If you supply inaccurate information, you face penalties even though you weren’t the filing party.⁴ One difference from a standard transaction: in a routed export, the USPPI is not required to provide the FPPI’s agent with a power of attorney. That authorization flows from the FPPI to its own agent.

What Data You Need to Submit

EEI is data-intensive. Every filing requires a core set of mandatory elements plus conditional fields depending on the shipment:

USPPI name, address of origin (no P.O. boxes), Employer Identification Number, and contact information for the person most knowledgeable about the shipment
Ultimate consignee name and address abroad
Date of export from the U.S. port on the exporting carrier
Commodity classification: the Schedule B or Harmonized Tariff Schedule (HTS) number for each commodity, with a commercial description detailed enough for agencies to verify the classification
Quantity, value, and unit of measure for each commodity line
U.S. state of origin as a two-character postal code
Country of ultimate destination, meaning where the goods will be consumed, processed, stored, or manufactured
Method of transportation and carrier identification (SCAC for vessel, rail, and truck; IATA code for air)
Port of export
Export information code identifying the type or condition of the transaction

For controlled goods, the filing must include the export license number, the applicable license exception, or a “No License Required” (NLR) designation. A related-party indicator is required when the USPPI and ultimate consignee have a 10 percent or greater ownership stake in each other.⁵

Schedule B or HTS

Schedule B and HTS codes are both 10 digits and share the same first six from the international Harmonized System. They diverge in the last four digits and in purpose. Schedule B numbers, maintained by the Census Bureau, are used for export statistical reporting in AES. HTS codes, maintained by the U.S. International Trade Commission, classify imports and determine duties. Either code is accepted in EEI, though exporters typically use Schedule B. The Census Bureau’s free Schedule B Search Engine handles lookups.

Screening the Foreign Parties

Before filing, screen every foreign party in the transaction against the Consolidated Screening List (CSL) maintained by the Departments of Commerce, State, and the Treasury. The CSL pulls multiple restricted-party lists into one search. A match against a listed party can mean a full export prohibition, a license requirement, or additional due diligence, depending on which list flagged the party.⁶ Skipping this step is one of the fastest ways to create a serious enforcement problem.

Filing Deadlines by Mode of Transport

The regulations set specific windows for when EEI must be filed and the filing citation given to the carrier before departure. Miss them and the carrier cannot legally load your goods:

Vessel: 24 hours before loading cargo at the U.S. port
Air, including express couriers: 2 hours before scheduled departure
Truck, including express consignment couriers: 1 hour before the truck arrives at the U.S. border
Rail: 2 hours before the train arrives at the U.S. border
Mail: 2 hours before exportation
Pipeline: within 4 calendar days after the end of each calendar month

These apply to predeparture filings, which is the standard method.⁷ The vessel deadline is the one that trips people up. It’s 24 hours before loading, not before sailing, which means your filing has to be ready well before the cargo reaches the port.

Post-departure filing exists as a limited privilege. Approved USPPIs can file up to five calendar days after goods leave the country, but the USPPI must apply directly to the Census Bureau (an agent cannot apply for you) and the application goes through multi-agency review with a target response of 90 days.⁸ Certain shipment types are excluded even for approved filers.

How to Submit Through AESDirect

EEI goes through AESDirect, a web application inside the Automated Commercial Environment (ACE) portal run by Customs and Border Protection. Log into ACE at ace.cbp.gov, go to the References tab, and select AESDirect. You need an active ACE account, which requires a one-time registration.

The filing walks through four sections: shipment details (mode, port of export, departure date, destination country), party information (USPPI, ultimate consignee, and any intermediate consignee or freight forwarder), commodity data (Schedule B or HTS code, description, quantity, value, license information), and transportation details. High-volume exporters can bypass the web interface by connecting through Electronic Data Interchange or specialized trade compliance software that transmits directly to AES.

When AES accepts the filing, it immediately returns an Internal Transaction Number. The ITN is the official proof of acceptance and the filing citation you or your agent must provide to the exporting carrier.⁹ The carrier needs the ITN, or an applicable exemption legend, noted on the bill of lading, air waybill, or other export documentation before loading. No ITN, no loading. Carriers face their own penalties for moving goods without a valid filing citation.

Penalties for Getting It Wrong

Penalties run both civil and criminal. Anyone who knowingly fails to file or knowingly submits false or misleading information faces fines up to $10,000 per violation, imprisonment up to five years, or both. The same penalties apply to using AES to further any illegal activity.¹⁰

Civil penalties are tiered:

Failure to file: up to $10,000 per violation. A submission counts as a failure once it’s more than 10 calendar days past the deadline, even if eventually filed.
Late filing: up to $1,100 for each day delinquent, capped at $10,000 per violation.
False or misleading information: up to $10,000 per violation, which can stack on top of other penalties.

Those are the baseline penalties under the FTR and 13 U.S.C. § 305.¹¹ If the export also violates the Export Administration Regulations or ITAR, fines escalate sharply under those separate enforcement regimes, potentially reaching hundreds of thousands of dollars per violation. FTR penalties are the floor.

Record Retention

All parties to the export transaction, including the USPPI, any FPPI, authorized agents, and carriers, must retain documents related to the shipment for five years from the date of export. That covers the EEI data itself, shipping documents, invoices, orders, packing lists, and related correspondence.¹² The Census Bureau, CBP, Immigration and Customs Enforcement, BIS, and other agencies can demand production at any point in that five-year window. If a different regulatory agency, such as the State Department for ITAR-controlled exports, imposes a longer retention period, the longer period controls.

1
eCFR. 15 CFR 30.2 – General Requirements for Filing Electronic Export Information (EEI)
2
eCFR. 15 CFR 30.37 – Miscellaneous Exemptions
3
eCFR. 15 CFR 30.36 – Exemption for Shipments Destined to Canada
4
eCFR. 15 CFR 30.3 – Electronic Export Information Filer Requirements, Parties to Export Transactions, and Responsibilities of Parties to Export Transactions
5
eCFR. 15 CFR 30.6 – Electronic Export Information Data Elements
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International Trade Administration. Consolidated Screening List
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eCFR. 15 CFR 30.4 – Electronic Export Information Filing Procedures, Filing Applications, and Post-Departure Filing Citations
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eCFR. 15 CFR 30.5 – Electronic Export Information Filing Processes and Responsibilities of Parties to Export Transactions
9
U.S. Census Bureau. Electronic Export Clearance: Requirements and Filing Process
10
Office of the Law Revision Counsel. 13 USC 305 – Penalties for Unlawful Export Information Activities
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GovInfo. 15 CFR 30.71 – False or Fraudulent Reporting on or Misuse of the Automated Export System
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eCFR. 15 CFR 30.10 – Retention of Export Information and the Authority to Require Production of Documents