NOEEI codes are the exemption legends you place on a bill of lading, air waybill, or other shipping document to show that a U.S. export does not require Electronic Export Information (EEI) filing through the Automated Export System (AES). Each code points to the section of the Foreign Trade Regulations (15 CFR Part 30) that authorizes the exemption. The most common is NOEEI 30.37(a), which covers goods valued at $2,500 or less per commodity classification code. Others cover shipments to Canada, tools of trade, military consignments, and a handful of narrower situations. None of them apply if the goods fall into a category that always requires filing.
What a NOEEI Code Actually Is
When an export requires EEI, the exporter or an authorized agent transmits the data through AES and receives an Internal Transaction Number (ITN) that goes on the shipping paperwork. When an export does not require EEI, the paperwork instead carries a short notation explaining why the filing was skipped. That notation is the exemption legend, and it uses the prefix “NOEEI” followed by the regulatory citation.1U.S. Census Bureau. Filing Citations and Exemption Legends
Carriers will not move cargo without either an ITN or a valid exemption legend on the documents, so picking the right NOEEI code is a routine part of preparing an export shipment.
The NOEEI Codes You’ll Actually Use
NOEEI 30.37(a) — Low-Value Shipments
This is the workhorse. It applies when the value of goods under a single Schedule B or Harmonized Tariff Schedule (HTS) commodity code is $2,500 or less on one shipment.2eCFR. 15 CFR 30.37 – Miscellaneous Exemptions The threshold is per commodity code, not per shipment total. A shipment worth $8,000 overall can still qualify if no single commodity code crosses $2,500.
The reverse also works. If a shipment mixes codes, only the codes over $2,500 need EEI filing; the ones under stay exempt.2eCFR. 15 CFR 30.37 – Miscellaneous Exemptions Items of domestic and foreign origin sharing the same code are counted separately, and filing kicks in if either category crosses the threshold.
Splitting an order across boxes to duck under $2,500 does not work. The regulations define a shipment as all goods going from one exporter to one consignee in a single country, on a single conveyance, on the same day.3U.S. Census Bureau. Frequently Asked Questions of the Foreign Trade Regulations Same truck, same day, same buyer means the values combine.
NOEEI 30.36 — Shipments to Canada
Goods with Canada as their final destination are generally exempt.4eCFR. 15 CFR 30.36 – Exemption for Shipments Destined to Canada Two situations pull the exemption back:
- Goods sent to Canada for storage when the ultimate destination is a third country.
- Goods moving from the U.S. through Canada to a third country.
The Canada exemption also does not override the mandatory filing categories below. A used car sold to a buyer across the border still needs an AES filing.
NOEEI 30.37(b) — Tools of Trade
Professional equipment or software carried abroad for work can qualify.2eCFR. 15 CFR 30.37 – Miscellaneous Exemptions To use it, the items must be owned by the exporter or their company, must accompany the traveler, cannot be for sale, cannot move under a bill of lading or air waybill, and must return to the U.S. within one year. A photographer carrying camera gear to an overseas shoot fits. Sending the same gear ahead as cargo does not.
NOEEI 30.37(c) — Transit Through Canada or Mexico
Shipments moving between two U.S. points on a route that passes through Canada or Mexico are exempt, since they are domestic shipments rather than exports.2eCFR. 15 CFR 30.37 – Miscellaneous Exemptions
NOEEI 30.37(f) — Technology and Software Without a License
Exports of technology and software that do not require an export license are generally exempt, with mass-market software as the main carve-out.2eCFR. 15 CFR 30.37 – Miscellaneous Exemptions
NOEEI 30.37(p) — Baggage and Personal Effects
Accompanied or unaccompanied baggage of people leaving the country is exempt if it does not move under a bill of lading or air waybill and does not require an export license. Travelers should be ready to declare orally to CBP if asked.
NOEEI 30.39 — U.S. Armed Services
Goods consigned to the U.S. Armed Services for their exclusive use are exempt.5eCFR. 15 CFR 30.39 – Special Exemptions The exemption does not reach ITAR-controlled items or goods not directly consigned to the military.
Household Goods (15 CFR 30.38) — A Reduced Filing, Not an Exemption
Household goods for someone relocating abroad get a reduced reporting requirement rather than a NOEEI legend. EEI must still be filed, but the filer does not have to provide commodity classification codes or the domestic/foreign origin indicator.6eCFR. 15 CFR 30.38 – Exemption From the Requirements for Reporting Complete Commodity Information The goods must be for the exporter’s own use in a dwelling abroad, not for resale.
When You Cannot Use Any NOEEI Code
Certain shipments require EEI filing regardless of value, destination, or any other exemption. These override both the $2,500 threshold and the Canada exemption. Under 15 CFR 30.2(a)(1)(iv), the mandatory filing categories include:7eCFR. 15 CFR 30.2 – General Requirements for Filing Electronic Export Information
- Goods requiring a Bureau of Industry and Security export license under the Export Administration Regulations.
- Items on the U.S. Munitions List, whether they require a Directorate of Defense Trade Controls license or are exempt from licensing. License-exempt is not filing-exempt.
- Goods requiring a Drug Enforcement Administration export permit.
- Goods requiring a Nuclear Regulatory Commission export license.
- Shipments to countries in Country Group E:1.
- Any item for which any federal agency requires an export license.
- Rough diamonds under HS subheadings 7102.10, 7102.21, and 7102.31, as part of the Kimberley Process.8U.S. Census Bureau. How to Export a Rough Diamond
- Used self-propelled vehicles. EEI must be filed at least 72 hours before export regardless of value, condition, or destination.9U.S. Customs and Border Protection. Exporting Used Self-Propelled Vehicles
The used vehicle rule catches people out most often. Someone selling a $1,200 car to a buyer in Canada might assume both the low-value exemption and the Canada exemption apply. Neither does. The vehicle needs a full AES filing 72 hours before it crosses the border.
A Note on Puerto Rico and U.S. Territories
Shipments between the mainland and Puerto Rico or the U.S. Virgin Islands count as export transactions for EEI purposes.10International Trade Administration. Shipping to Puerto Rico and Other U.S. Territories The $2,500 threshold and the mandatory filing categories apply the same way they do to foreign exports.
How to Format and Place the Legend
The exemption legend must appear on the first page of the bill of lading, air waybill, or other commercial loading document, and on the carrier’s outbound manifest.11eCFR. 15 CFR 30.35 – Exemption Legends Write it as “NOEEI” followed by the regulatory citation:
- NOEEI 30.37(a) — low-value shipment ($2,500 or less per commodity code)
- NOEEI 30.36 — shipment to Canada
- NOEEI 30.37(b) — tools of trade
- NOEEI 30.39 — U.S. Armed Services exclusive use
Most shipping platforms have a dedicated field for either the AES ITN or the exemption legend. Before you generate labels or manifests, confirm the exemption you selected actually applies and that no mandatory filing category overrides it. Applying the wrong NOEEI code to a shipment that should have been filed is treated as a failure to file.
Recordkeeping and Penalties
Every party to an export transaction must keep supporting documents for five years from the date of export, including exporters, freight forwarders, carriers, and agents.12eCFR. 15 CFR 30.10 – Retention of Export Information and the Authority to Require Production of Documents Records include EEI filings or exemption legends, invoices, packing lists, bills of lading, purchase orders, and related correspondence. If another agency requires a longer retention period for the type of goods involved, that longer period controls. Claiming an exemption does not reduce this obligation, and clean records of why you qualified are your best protection in an audit.
Civil penalties for late filing, failing to file, or filing inaccurate information can reach up to $10,000 per violation. Criminal penalties under 15 CFR 30.71 apply to failures to file, false information, and misuse of AES.13eCFR. 15 CFR 30.71 – False or Fraudulent Reporting on or Misuse of the Automated Export System Exposure is not limited to the exporter. Forwarders, carriers, and authorized agents can face enforcement if they move cargo without a valid ITN or a properly formatted exemption legend, which is why carriers refuse shipments that lack one or the other.