AES and EEI Explained: How US Export Filing Works

Under the Foreign Trade Regulations, most physical goods leaving the United States need Electronic Export Information (EEI) filed in the Automated Export System (AES) before they move, and the filer receives an Internal Transaction Number (ITN) that has to travel with the cargo. The EEI is the modern form of the old paper Shipper's Export Declaration. Get it wrong or late and the carrier may refuse to load, and the penalties fall on the filer, not only on the exporter. This guide is based on the text of 15 CFR Part 30 as published on the eCFR, current to 20 September 2026.

What the EEI and AES actually are

The AES is the electronic system through which export data is collected. The regulation says it is the system for collecting Shipper's Export Declaration information "or any successor document", and for the purposes of Part 30 that information is simply called EEI (15 CFR 30.2(a)(1)). It exists mainly to produce US trade statistics and to support export controls enforcement, which is why it asks about classification, value and end destination rather than about duties.

Two points that trip people up. First, the filing obligation covers exports of physical goods, including orders received over the internet. Second, it covers more than shipments to foreign countries: movements between the United States and Puerto Rico, and to the US Virgin Islands, are also within the AES scope (30.2(a)(1)).

When an EEI is required, and when it is not

The default is that an EEI is required. Everything else is an exclusion or an exemption, and the two are different things. Exclusions in 30.2(d) are transactions outside the scope of Part 30 altogether, such as goods moving in transit through the United States from one foreign country to another without entering for consumption or warehousing, and electronic transmissions and intangible transfers. Exemptions in Subpart D are shipments that are in scope but that need no filing.

The $2,500 rule

The best-known exemption is in 15 CFR 30.37(a). No EEI is required where the value of the commodities shipped from one USPPI to one ultimate consignee on a single exporting conveyance, classified under an individual Schedule B number, is $2,500 or less. The test applies per Schedule B number, regardless of the total shipment value. Three details matter in practice:

• Mixed shipments: if some Schedule B lines are over $2,500 and some are under, only the lines over $2,500 must be reported.
• Same number, several items: if you ship multiple items under the same Schedule B number, the exemption applies only if the combined value for that number is $2,500 or less.
• Domestic and foreign origin: goods of domestic and foreign origin under the same classification number are reported separately, and an EEI is required when either is over $2,500.

The exemption is also not a blanket permission. Section 30.37 opens with "except as noted in 30.2(a)(1)(iv)", and that paragraph lists shipments that need an EEI regardless of value.

Shipments that need an EEI at any value

Under 30.2(a)(1)(iv), an EEI is required whatever the value for goods that:

• need a Bureau of Industry and Security (BIS) licence, or require reporting under the Export Administration Regulations;
• need a State Department licence under the ITAR, or are subject to the ITAR but licence-exempt;
• need a Drug Enforcement Administration permit or declaration, or a Nuclear Regulatory Commission licence;
• need an export licence from any other federal agency;
• are rough diamonds under HS subheadings 7102.10, 7102.21 or 7102.31;
• are used self-propelled vehicles as defined in 19 CFR 192.1.

Other common exemptions

A few others come up often. Shipments originating in the United States whose country of ultimate destination is Canada are generally exempt (30.36), but not goods sent to Canada for storage and ultimately bound for a third country, nor goods moving through Canada to a third destination. Shipments consigned to the US Armed Services for their exclusive use are exempt unless the articles are on the US Munitions List (30.39). Section 30.37 also covers tools of trade under conditions (owned by the exporter, not for sale, returned within one year and not shipped under a bill of lading or air waybill), most technology and software not needing a licence (but not mass-market software), and a list of other narrow categories. Read the section against your facts rather than relying on a summary, because the conditions are specific.

Who files: the USPPI, the agent, and routed transactions

The filer is either the USPPI (United States Principal Party in Interest) or an authorised agent (30.3(a)). The USPPI is the person in the United States that receives the primary benefit, monetary or otherwise, from the transaction. Section 30.3(b)(2) works through the scenarios: a manufacturer selling directly to a foreign buyer is the USPPI; a US wholesaler who buys domestically and then sells for export is the USPPI; a US order party arranging the sale and export is the USPPI. Special rules cover customs brokers re-exporting imported goods and Foreign Trade Zone admissions.

Three rules on the filer are worth memorising:

• A foreign entity that is the USPPI cannot file the EEI itself and must authorise an agent (30.3(a)(1)).
• The filer needs a physical office or residence in the United States, must be physically in the United States when filing, and must have an EIN or DUNS and be certified to report in the AES (30.3(a)(2)).
• Incoterms and other commercial terms do not decide who the USPPI is. The regulation says international commercial terms and industry agreements have no regulatory basis for determining the type of transaction or the parties (30.3, opening paragraph). An EXW or FOB label in your sales contract does not move the filing responsibility.

Filing through an agent

Most forwarders file on behalf of exporters. The USPPI must give the agent a power of attorney or written authorisation to file, and must supply accurate and timely information (30.3(c)(1)). The agent must obtain that authority, file accurately and on time based on what it receives, and keep supporting documents (30.3(c)(2)). The regulation notes that a power of attorney should specify the parties' responsibilities with particularity and state that the agent may act as a true and lawful agent for creating and filing EEI. The USPPI keeps its own duty to retain documents supporting what it gave the agent.

Routed export transactions

In a routed export transaction the foreign buyer (the FPPI) authorises a US agent to arrange the export and prepare and file the EEI, typically because the buyer controls the freight (30.3(e)). Responsibility shifts in three ways:

• The agent's authority comes from the foreign buyer, not the USPPI, and the USPPI is not required to give the agent a power of attorney.
• The USPPI must still supply complete, accurate and timely export information and keep supporting records. Appendix C to Part 30 lists the data the USPPI provides, and the agent must file it exactly as provided.
• Routed transactions must always be filed predeparture (30.4(a)(5)), so the postdeparture option is not available.

The foreign buyer can also agree to let the USPPI file, but only with a written authorisation assuming responsibility, and the filing is then still treated as routed. For the licensing side, the US agent of the buyer may be the "exporter" for export control purposes, a distinction the regulation explicitly preserves. See our guide to restricted party screening and export controls for what that means before you release goods.

What data goes into an EEI

Section 30.6 lists the data elements. There are 28 mandatory ones, plus conditional and optional elements. At a plain-language level they answer these questions:

Some of these are worth understanding rather than just typing:

• Ultimate consignee: where the end user's name and address is known, the end user is the ultimate consignee. Where the foreign buyer is a reseller or distributor and the end user is unknown or the goods sit in inventory, the foreign buyer is the ultimate consignee (30.6(a)(3)). A freight forwarder abroad or a bank is not the ultimate consignee.
• Value: in general it is the value of the goods at the US port of export: the selling price (or cost, if not sold) plus inland freight, insurance and other charges to the US seaport, airport or land border port of export (30.6(a)(17)). It is not the invoice total of an ocean-freight-inclusive sale, and it is not the customs value the importing country uses. Our guide to customs valuation explains why the import side uses a different basis.
• Commodity classification: the 10-digit Schedule B number, or the HTSUSA number in lieu of it except where the HTSUSA headnotes say otherwise. A correct number does not relieve you of giving a complete and accurate description (30.6(a)(12)). For the wider classification discipline, see HS codes explained.

The ITN and where it must appear

When the AES accepts a filing it returns a confirmation number, the Internal Transaction Number. The proof of filing citation is the letters AES followed by the ITN. Appendix B to Part 30 gives the example format "AES X20170101987654". The filer must put the citation, or the right exemption legend, on the first page of the bill of lading, air waybill, export shipping instructions or other commercial loading document, clearly visible (30.7(b)). The legends in Appendix B include:

The ITN is also what you quote when correcting a filing or when a split shipment needs a reference to the original.

Filing deadlines by mode

Section 30.4(b)(2) sets the timing for non-USML shipments filed predeparture. The filer must have filed and received the ITN, and provided the citation or legend to the exporting carrier, by these times:

Used self-propelled vehicles have their own rule: the filing citation goes to CBP at least 72 hours before export (30.4(b)(4)). Paragraph numbering in 30.4 has changed with recent amendments, so cite the section as currently published rather than from older agency material. USML shipments follow the ITAR timing in 22 CFR 123.22(b)(1). Shipments between the United States and Puerto Rico need the citation to the carrier by the time the shipment arrives at the port of unlading (30.4(b)(3)).

Postdeparture filing

Approved USPPIs may file up to five calendar days after the date of export on non-pipeline modes (30.4(c)(1)), but only if they hold that authorisation, and never for shipments where predeparture filing is mandatory. The mandatory list in 30.4(a) includes used vehicles, USML items, shipments needing a BIS or Nuclear Regulatory Commission licence, routed export transactions and any shipment where the USPPI has not been approved for postdeparture filing. If you are not approved, assume predeparture.

How to file: AESDirect, software, or an agent

Section 30.2(a)(2) gives the USPPI four means: use AESDirect, develop AES software to CBP's AESTIR specification, buy certified vendor software, or use an authorised agent. AESDirect users create an ACE Exporter Account and agree to the AES certification statements. Filers using other methods submit a Letter of Intent to CBP and may need to pass certification. If AES itself is unavailable, the downtime rules apply: the filer either delays the export or uses an alternative method, or exports with the AESDOWN citation and files at the first opportunity. That downtime shortcut does not apply to the shipments the regulation ties to mandatory predeparture licensing, where no ITN means no export.

Carrier and forwarder responsibility: no ITN, no loading

The carrier must not load or move cargo unless the required documentation carries the AES proof of filing, postdeparture, downtime, exclusion or exemption citation, and that citation must be on the first page of the bill of lading or air waybill (30.3(c)(3)). The carrier annotates its outbound manifest where required and presents the citation to the CBP port director at the port of export without altering it. If transport data changes, the carrier notifies the filer, who must transmit corrections as soon as they are known (30.9).

For a forwarder this means two things. When you act as the agent, you are the filer and the deadline is yours. When you are simply booking the cargo, you should still ask for the citation or legend before the cargo gates in, because a cut-off missed for want of an ITN is a rolled shipment. Our guide on customs brokers versus forwarders covers who normally handles which filing.

Corrections, penalties and record retention

Corrections

Fatal errors, where the AES rejects a filing, must be corrected and resubmitted before export for predeparture filings, or within five calendar days after export for postdeparture ones. Warning and verify messages should be corrected within four calendar days of receipt. A compliance alert means the shipment was not reported in accordance with the regulation, and the filer must review its filing practices (30.9(b)).

Penalties

Subpart H sets the penalties, and the statutory basis includes 13 U.S.C. sections 304 and 305. As printed in 30.71:

• Criminal: knowingly failing to file, or knowingly submitting false or misleading export information, is punishable by a fine of up to $10,000, imprisonment of up to five years, or both, per violation, plus forfeiture of interests in the goods and proceeds (30.71(a)).
• Civil, failure to file: up to $10,000 per violation. A filing made more than ten calendar days after the due date is also treated as a failure to file (30.71(b)(1)).
• Civil, late filing: up to $1,100 for each day of delinquency, capped at $10,000 per violation (30.71(b)(2)).
• Other civil violations: up to $10,000 per violation (30.71(b)(3)).

The regulation states that the civil amounts are adjusted for inflation each year and published in the Federal Register by 15 January, so the figure that applies today can be higher than the text above. Treat those numbers as the floor of your awareness and check the current adjustment. Also note that penalties reach USPPIs, authorised agents, carriers and any other person subject to the rules (30.2(e)), and that the filer is responsible for complete, accurate and timely EEI except where it can show it reasonably relied on information from other responsible persons based on personal knowledge (30.3(a)(3)).

Record retention

All parties to the export, meaning USPPIs, foreign principals, authorised agents and carrier owners and operators, must keep documents pertaining to the shipment for five years from the date of export, and longer where the State Department or another agency requires it (30.10(a)). During that period Census, CBP, ICE, BIS and other agencies may ask for the EEI, invoices, orders, packing lists and correspondence. If you later claim refunds on exported goods, the same records support the claim, as covered in duty drawback explained.

Common errors and how to avoid them

• Wrong Schedule B number: copying the import tariff code from the supplier's paperwork without checking that the export classification is correct. Classify against the goods, and keep the reasoning.
• Wrong value basis: reporting the CIF or delivered price, or the full invoice with foreign freight included, rather than the value at the US port of export. Remember that the value includes US inland freight to the port and excludes foreign freight and insurance beyond it.
• Wrong ultimate consignee: naming the foreign forwarder, freight agent or bank instead of the party that receives the shipment. The end user is the ultimate consignee if known.
• Treating $2,500 as a shipment threshold: it is applied per Schedule B number, per USPPI to one ultimate consignee, per exporting conveyance, and licensed goods are always in.
• Assuming the Incoterm allocates the filing: selling EXW does not make the buyer the filer, and it does not stop the US seller being the USPPI.
• Ignoring AES messages: unanswered warnings and verify messages become violations after four days.
• Skipping the citation on the loading document: an accepted filing with no ITN on the bill of lading still leaves the carrier unable to load.

EEI is not the export declaration of other countries

Do not assume that an EEI covers the destination or any other country's customs formalities. The EEI is the US government's own export record. Other countries run their own export declarations, with their own forms, systems, deadlines and data, and the destination's import declaration is a separate filing again. If your goods are shipped from the United States to a country that requires an export clearance in the origin only, the EEI covers that US step, while the import filing and duties in the destination remain a distinct process. See customs clearance explained for how the import side works.

What to do next

1. Decide who the USPPI is for each transaction using 30.3(b), not the Incoterm.
2. Screen the ultimate consignee and check licensing before you file. Our restricted party screening guide explains why.
3. Classify the goods to a 10-digit number and calculate the value at the US port of export.
4. Give your forwarder a written power of attorney with clear scope, and agree who files and by when, remembering the mode deadline in the table above.
5. Put the AES citation or exemption legend on the first page of the loading document and keep the ITN with your records for five years.

If you need help with filing, look for a forwarder or customs broker who handles US exports and can show you how they prepare the EEI and what they need from you. You can search the CargoLinked directory by country and service and check each company's credentials yourself, or post your shipment on the requests board and let eligible forwarders send quotes, each with a validity date.

This guide reflects 15 CFR Part 30 as published on the eCFR in September 2026 and is general information, not legal advice. Penalty amounts are adjusted annually. Confirm the current text and your own facts with the Census Bureau, CBP or a qualified adviser before you file.