Export Compliance

AES / EEI Filing Guide

Every US export valued over $2,500 per Schedule B code — or involving controlled goods — requires an Electronic Export Information (EEI) filing through the Automated Export System. Get it wrong and penalties start at $10,000 per violation.

$2,500 per Schedule B
Filing Threshold
Up to $10,000
Criminal Penalty
Before Export
Filing Deadline

What Is AES / EEI Filing?

The US export reporting requirement administered by the Census Bureau and enforced by BIS and CBP.

The Automated Export System (AES) is the US government's electronic system for collecting export data. The information you file in AES is called the Electronic Export Information (EEI) — it replaced the old paper Shipper's Export Declaration (SED) in 2008.

EEI filing is required for most US exports when the value of goods in a single Schedule B classification exceeds $2,500, when goods require an export license (EAR/ITAR), or when the destination is a sanctioned or embargoed country — regardless of value.

As a freight forwarder, you are often designated as the 'authorized agent' to file EEI on behalf of the US principal party in interest (USPPI). This makes you directly responsible for accurate and timely filing — even if the shipper provides the data.

When Is EEI Filing Required?

Not every export needs an EEI. Know the triggers to avoid over-filing or — worse — missing a required filing.

Value Threshold: $2,500+

When the value of goods in a single Schedule B classification exceeds $2,500 to a single consignee on a single export date. This is per commodity line, not per shipment.

Export License Required

ALL shipments requiring an export license under EAR or ITAR need EEI filing regardless of value. Even a $100 controlled item requires filing.

Sanctioned Destinations

All exports to countries under US sanctions or embargoes require EEI filing regardless of value. Currently includes Cuba, Iran, North Korea, Syria, and parts of other countries.

Rough Diamonds

All exports of rough diamonds require EEI filing under the Kimberley Process, regardless of value.

Used Self-Propelled Vehicles

All used vehicles being exported require EEI filing regardless of value, including cars, trucks, buses, and motorcycles.

Common Filing Exemptions

These exemptions let you skip EEI filing — but you must cite the correct exemption code on the bill of lading.

Low Value (30.37(a))

NO EEI 30.37(a)

Commodities valued at $2,500 or less per Schedule B to a single consignee — unless a license is required, goods are controlled, or the destination is sanctioned.

Canada (30.36)

NO EEI 30.36

Most exports to Canada are exempt from EEI filing. Exceptions: goods requiring a US export license, goods controlled for anti-terrorism, and rough diamonds.

Personal Effects (30.37(b))

NO EEI 30.37(b)

Household goods and personal effects of the exporter, not for resale. Includes personal belongings of people moving abroad.

Diplomatic Pouches (30.37(e))

NO EEI 30.37(e)

Shipments by US government agencies and diplomatic pouches are exempt under specific conditions.

Return/Replacement (30.37(h))

NO EEI 30.37(h)

Goods being returned or replaced under warranty, provided original import documentation is available and the goods are not controlled.

How to File EEI — Step by Step

The filing process from classification to ITN.

1

Classify Goods — Schedule B Code

Assign the correct 10-digit Schedule B number for each commodity. Use the Census Bureau's Schedule B Search Engine. The Schedule B is based on the HS code but has additional US-specific digits. Incorrect classification is one of the most common violations.

2

Screen All Parties

Check the buyer, consignee, and end-user against the Consolidated Screening List (CSL). This includes the Entity List, Denied Persons List, SDN List, and others. A match doesn't automatically prohibit the export but requires further investigation.

3

Determine License Requirements

Check if the goods are controlled under EAR (Commerce Control List) or ITAR (US Munitions List). Cross-reference the ECCN or USML category with the destination country and end-use. Most commercial goods are EAR99 (no license required).

4

File in AESdirect

Enter the shipment data in AESdirect (free Census Bureau portal) or through your integrated TMS/customs software. Required data includes: USPPI, consignee, Schedule B, value, quantity, country of destination, export carrier, and license information.

5

Receive the ITN

Upon successful filing, AES returns an Internal Transaction Number (ITN) — a unique 14-character code (format: X20250407123456). This ITN must be provided to the carrier and appear on shipping documentation.

6

Provide ITN to Carrier

The carrier needs the ITN (or exemption citation) before the goods are exported. For ocean freight, this means before vessel departure. For air freight, before the aircraft leaves. The carrier is prohibited from exporting without a valid ITN.

AES / EEI Penalties

Export violations carry serious penalties — both civil and criminal. Census Bureau, BIS, and CBP all have enforcement authority.

Late Filing

$1,100 per day

Filing the EEI after the export date. Penalties accrue per day late, per shipment. The Census Bureau actively monitors for late filings.

Failure to File

Up to $10,000

Not filing when required. Civil penalty of up to $10,000 per violation. Criminal penalty of up to $10,000 and/or 5 years imprisonment for willful violations.

Filing False Information

Up to $10,000

Intentionally filing incorrect data — wrong value, wrong Schedule B, wrong consignee. Criminal penalties can include imprisonment. This is where the serious enforcement happens.

Export Without ITN

$10,000 per shipment

Exporting goods without a valid ITN or exemption citation on the bill of lading. Both the forwarder and the carrier can be penalized.

EAR / ITAR Violations

$300,000+ per violation

Exporting controlled goods without the required license. BIS civil penalties up to $300,000 per violation. ITAR violations up to $1,000,000 per violation. Criminal penalties include imprisonment.

Frequently Asked Questions

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