What Is ITN in Shipping? Filing Rules, Deadlines, and Penalties

An Internal Transaction Number, or ITN, is the confirmation code the Automated Export System (AES) generates after a shipper successfully submits Electronic Export Information (EEI) for an outbound U.S. shipment.¹ In shipping, the ITN is your proof that the federal government has accepted and recorded the export filing, and carriers are legally prohibited from loading cargo onto international transport without it or an applicable exemption legend on the shipping documents. Filing obligations are set out in the Foreign Trade Regulations at 15 CFR Part 30.

When You Need an ITN

The main trigger is value. If any single commodity in your shipment exceeds $2,500 based on its Schedule B or Harmonized Tariff Schedule classification, you must file EEI and obtain an ITN before the goods leave the country.² The threshold applies per commodity type, per consignee, per conveyance. A shipment with three different commodity codes each worth $2,000 does not trigger the requirement. A single commodity worth $2,501 does.

Value is not the only trigger. You must file regardless of value when:

The goods need an export license from the Bureau of Industry and Security or from the State Department’s Directorate of Defense Trade Controls under the International Traffic in Arms Regulations.²
The destination appears in Country Groups E:1 or E:2 (Supplement No. 1 to 15 CFR Part 740), unless a specific exemption applies and no license is required. These country groups cover nations subject to comprehensive U.S. export restrictions, and the list changes, so verify the current supplement before assuming your destination is clear.³
The items sit on the U.S. Munitions List. USML shipments must always be filed predeparture, on deadlines set by the ITAR rather than the standard AES timeframes.⁴

When an ITN Is Not Required

When a shipment qualifies for an exemption, you place an exemption legend on the shipping documents instead of an ITN. The legend starts with “NOEEI” followed by the regulatory citation that applies.

Low-Value Shipments

If every commodity in your shipment falls at or below $2,500 per Schedule B classification, and the shipment does not require a license or fall under a country-group restriction, use the legend NOEEI § 30.37(a) on your bill of lading or air waybill.⁵ This is the most commonly used exemption in practice.

Shipments to Canada

Exports destined for Canada are generally exempt and can use NOEEI § 30.36. The exemption does not apply if the goods require an export license, are sent to Canada for storage but ultimately headed to a third country, or are moving through Canada to another destination.⁶

Other Legends

Additional NOEEI legends cover shipments to U.S. Armed Forces (NOEEI § 30.39), certain U.S. government agency exports (NOEEI § 30.40), and other miscellaneous categories.⁵

Filing Deadlines by Transport Mode

The deadlines are tighter than most new filers expect, and they vary by how the cargo is leaving the country:

Vessel cargo: file EEI and provide the citation to the carrier at least 24 hours before cargo is loaded at the U.S. port.
Air cargo: file at least 2 hours before the aircraft’s scheduled departure.
Truck cargo: file at least 1 hour before the truck arrives at the U.S. border.
Rail cargo: file at least 2 hours before the train arrives at the U.S. border.⁴

Shipments between the United States and Puerto Rico follow a different rule: the filing citation must be provided to the carrier by the time the shipment arrives at the port of unlading, rather than before departure.⁷

A limited postdeparture option exists, allowing EEI to be submitted up to five calendar days after export, but it is a privilege the USPPI must apply for through the Census Bureau, with review by multiple agencies and approval typically taking up to 90 days. It is not available for USML items or licensed exports.⁸

Information You Need Before You File

Missing any of these will generate errors and delay your ITN:

USPPI identification. The U.S. Principal Party in Interest is typically the seller or the entity receiving the primary benefit of the export. You must provide the USPPI’s Employer Identification Number, specifically the one used to report employee wages and withholdings. A Social Security Number is not accepted.⁹
Ultimate consignee: the party who will actually receive the goods in the foreign country.
Schedule B or HTS classification: the ten-digit code that classifies the goods. Getting this wrong is one of the fastest ways to create compliance problems.
Value and weight: commercial value of the goods, weight in kilograms.
Country of ultimate destination: where the goods end up, not just the first port they touch.
Port of export: the U.S. location where the cargo departs.
Export licensing information, if a license is required.

If the USPPI is a foreign entity physically present in the United States without an EIN, the authorized agent can report a border crossing number, passport number, or a CBP-assigned number instead.⁹

How Filing Works and How the ITN Comes Back

EEI is filed through the AESDirect application inside the Automated Commercial Environment (ACE) portal, which is managed by U.S. Customs and Border Protection.¹⁰ The USPPI or an authorized agent can file. You will need an ACE account and login credentials before you can access the filing screens.

Once logged in, you enter the required data elements into the EEI form. The system runs automated checks for logical errors, missing fields, and inconsistencies. If everything passes, the system generates the ITN within seconds and displays it in the portal dashboard or sends it by automated notification. If errors are flagged, correct them and resubmit before the ITN is issued.

In a routed export transaction, a foreign buyer controls the transportation and designates a U.S.-based authorized agent to prepare and file the EEI. In that arrangement, the agent (holding a power of attorney or written authorization) bears responsibility for filing complete and accurate EEI, while the USPPI still owes commodity classification and export licensing information to the agent.¹¹

Putting the ITN on Shipping Documents

The proof-of-filing citation follows a specific format: the letters “AES” followed by a space, then “X,” the acceptance date (YYYYMMDD), and six system-generated digits. A filing accepted on January 1, 2026 might read AES X20260101987654.¹

The citation must appear on the first page of the bill of lading, air waybill, or other commercial loading document. Carriers are legally required to verify that the citation (or an applicable exemption legend) is present before loading cargo. If it is missing, the carrier cannot move the freight onto international transport.¹¹ Many shippers also include the citation on the Shipper’s Letter of Instruction so every intermediary in the logistics chain has it.

For split shipments where cargo covered by a single filing moves on more than one conveyance, append “SS” to the end of the citation, for example AES X20260101987654 SS.⁵

Fixing Mistakes After Submission

The USPPI or authorized agent must transmit corrections, cancellations, or amendments as soon as new or corrected information becomes known. If AES returns a fatal error after goods have departed under a postdeparture filing, the corrected EEI must be resubmitted within five calendar days of the export date. Rejected update messages need to be corrected as soon as possible. Ignoring error messages and leaving filings uncorrected is itself a violation of the Foreign Trade Regulations.¹²

How Long to Keep the Records

Every party involved in an export transaction must retain all documents related to the shipment for five years from the date of export. That includes the EEI filing itself, shipping documents, invoices, orders, packing lists, and related correspondence. The Census Bureau, CBP, ICE, BIS, and other agencies can request these records at any point during that window. If the State Department or another regulatory agency imposes a longer retention period for a specific category of exports, that longer period controls.¹³ Defense articles under ITAR often carry longer retention requirements. Keep the ITN confirmation with the rest of your export file.

Penalties for Non-Compliance

Civil Penalties

The Foreign Trade Regulations set three tiers:

Late filing: up to $1,100 per day of delinquency, capped at $10,000 per violation.
Failure to file: up to $10,000 per violation. Any filing submitted more than ten calendar days past the deadline is treated as a failure to file, not a late filing.
False or misleading information and other violations: up to $10,000 per violation, in addition to any other penalties.¹⁴

These base amounts are adjusted annually for inflation under the Federal Civil Penalties Inflation Adjustment Act, so current maximums may be somewhat higher than the figures in the regulation text.

Criminal Penalties

Knowingly failing to file or knowingly submitting false export information carries a criminal fine of up to $10,000 per violation, imprisonment for up to five years, or both. Convicted individuals also face forfeiture of their interest in the goods and any proceeds from the violation.¹⁵ “Knowingly” is aimed at intentional violations rather than honest mistakes, but regulators read it broadly when a company has been warned before or when a pattern of non-filing suggests willful disregard.

1
United States Census Bureau. Filing in AESDirect: How Do You Find Your Internal Transaction Number?
2
eCFR. 15 CFR Part 30 – Foreign Trade Regulations
3
eCFR. 15 CFR 30.16 – Export Administration Regulations
4
eCFR. 15 CFR 30.4 – Electronic Export Information Filing Procedures, Deadlines, and Certification Statements
5
eCFR. Appendix B to Part 30 – AES Filing Citation, Exemption and Exclusion Legends
6
eCFR. 15 CFR 30.36 – Exemption for Shipments Destined to Canada
7
eCFR. 15 CFR 30.4 – Electronic Export Information Filing Procedures, Deadlines, and Certification Statements
8
eCFR. 15 CFR 30.5 – Electronic Export Information Filing Processes and Standards
9
eCFR. 15 CFR 30.6 – Electronic Export Information Data Elements
10
U.S. Customs and Border Protection. Introduction to the Automated Export System (AES)
11
eCFR. 15 CFR 30.3 – Electronic Export Information Filer Requirements, Parties to Export Transactions, and Responsibilities of Parties to Export Transactions
12
eCFR. 15 CFR 30.9 – Transmitting and Correcting Electronic Export Information
13
eCFR. 15 CFR 30.10 – Retention of Export Information and the Authority to Require Production of Documents
14
eCFR. 15 CFR 30.71 – False or Fraudulent Reporting on or Misuse of the Automated Export System
15
Office of the Law Revision Counsel. 13 USC 305 – Penalties for Unlawful Export Information Activities