AES and EEI Export Filing Basics for Ocean Exports


By GDZ Computer Services · Updated 2026-10-21 · 8 min read · Blog › U.S. Customs and compliance

Electronic Export Information (EEI) is the export data filed in the Automated Export System (AES) for most shipments leaving the United States. For ocean cargo, the filer must transmit the EEI and give the carrier the proof of filing 24 hours before the cargo is loaded at the U.S. port.

Key takeaways
  • The USPPI or its authorized agent files EEI in AES, the export component of CBP's ACE; ACE AESDirect is the free filing portal.
  • EEI is generally required when a single Schedule B or HTS line is valued over $2,500, and always when a license or certain other controls apply.
  • For vessel cargo, the EEI must be filed and the proof of filing given to the carrier 24 hours before loading at the U.S. port.
  • Shipments between the U.S. mainland and Puerto Rico, and to the U.S. Virgin Islands, are also covered.

What AES and EEI are

The Census Bureau describes the Automated Export System as the export component of CBP's Automated Commercial Environment (Census Bureau: AES). It collects Electronic Export Information, the data that used to go on the paper Shipper's Export Declaration. The rules live in the Foreign Trade Regulations, 15 CFR part 30, which the Census Bureau administers.

Filers can submit through ACE AESDirect, which Census calls the primary, free filing tool, or through a direct connection that requires completing the AES software certification process. Either way, when AES accepts a filing it returns an Internal Transaction Number (ITN), the confirmation that the export information was accepted.

Who files: USPPI, authorized agent and carrier

Under 15 CFR 30.2, EEI is filed by the United States Principal Party in Interest (USPPI), the USPPI's authorized agent, or the authorized U.S. agent of the Foreign Principal Party in Interest. The USPPI is the person in the United States that receives the primary benefit of the transaction, usually the U.S. seller. A U.S. manufacturer selling directly to a foreign buyer is the USPPI; if it sells domestically to a U.S. distributor that then exports, the distributor is.

The filer must have a physical office or residence in the United States, be in the U.S. when preparing and filing, have an EIN or DUNS number and be certified to report in AES. The filer is responsible for complete, accurate and timely data, except where it can show it reasonably relied on information from other parties.

PartyRole in AES
USPPI (usually the U.S. seller)Responsible for the EEI; files itself or authorizes an agent.
Authorized agent (often a forwarder or NVOCC)Prepares and transmits the EEI on the USPPI's behalf.
Exporting carrierReceives the proof of filing citation or exemption legend, annotates its outbound manifest when required and presents it to CBP.
Main parties under 15 CFR 30.2, 30.3 and 30.7.

When EEI is required, and the $2,500 rule

EEI is required for exports from the United States, Puerto Rico, U.S. foreign trade zones and the U.S. Virgin Islands to foreign countries. It is also required for shipments between the U.S. and Puerto Rico and to the U.S. Virgin Islands from the U.S. or Puerto Rico, which matters for every Florida carrier serving those trades.

The best-known exemption is in 15 CFR 30.37(a): no EEI is needed when the value shipped from one USPPI to one ultimate consignee on a single conveyance under an individual Schedule B or HTS number is $2,500 or less. The test is per classification number, not per shipment, so a mixed shipment may need EEI for some lines and not others.

Some shipments need EEI regardless of value. Section 30.2 lists, among others, exports that require a Commerce (BIS) license or EAR reporting, items subject to the State Department's ITAR, DEA export permits, Nuclear Regulatory Commission licenses, licenses from any other federal agency, rough diamonds, and used self-propelled vehicles.

Ocean deadlines and the ITN on the bill of lading

For vessel cargo, 15 CFR 30.4(b)(2)(i) requires the USPPI or agent to file the EEI and provide the filing citation or exemption legend to the exporting carrier 24 hours prior to loading the cargo on the vessel at the U.S. port. Two ocean cases are different:

  • U.S. and Puerto Rico shipments: the proof of filing or exemption legend must reach the exporting carrier by the time the shipment arrives at the port of unlading.
  • Used self-propelled vehicles: the EEI must be filed and the filing citation given to CBP at least 72 hours before export, and the carrier still needs the citation.

The proof of filing citation, built around the ITN, or the exemption legend goes on the first page of the bill of lading or other commercial loading document, clearly visible. The carrier annotates its outbound manifest with it when required and presents it to CBP at the port of export without material change.

Certain approved USPPIs can file on a postdeparture basis. The Census Bureau says previously approved companies may report EEI within 5 calendar days after export. Many shipment types, including licensed items and used vehicles, must always be filed before departure.

A step-by-step routine for ocean exports

For an NVOCC or forwarder handling exports as the USPPI's agent, a repeatable routine looks like this:

  1. Get written authorization from the USPPI to file on its behalf.
  2. Collect the USPPI and ultimate consignee details, Schedule B or HTS numbers, quantities, values and any license information at booking.
  3. Check each classification line against the $2,500 threshold and the list of always-file shipments.
  4. Transmit the EEI in AES and confirm you received an ITN, or document the exemption that applies.
  5. Put the proof of filing citation or exemption legend on the first page of the bill of lading and give it to the carrier at least 24 hours before loading.
  6. Keep the ITN with the booking and bill of lading so corrections and audits can find it.

Keeping that information on the same booking and bill of lading record avoids the classic failure: the ITN sits in someone's e-mail while the bill goes out without it. In a system such as GDZ-ISIS, the booking, dock receipt and bill of lading already share one record, so the parties and cargo details the filer needs are in one place.

Common AES mistakes on ocean shipments

Most AES problems on ocean exports come from a short list of misunderstandings, all of them addressed in 15 CFR part 30:

  • Listing the forwarder as the USPPI. The regulation says that in most cases the U.S. forwarding or other agent is not a principal party in interest.
  • Applying the $2,500 test to the whole shipment. It applies per Schedule B or HTS number. Items of domestic and foreign origin under the same number are reported separately, and EEI is required when either is over $2,500.
  • Letting Incoterms decide who files. Part 30 recognizes two types of export transactions, standard and routed, and says terms of sale do not determine the type or the parties.
  • Sending the bill of lading without the ITN. The proof of filing citation or exemption legend must appear on the first page of the loading document.

An NVOCC that files for many small exporters sees these errors every week. Building the checks into booking, rather than catching them at the documentation cutoff, is where NVOCC software earns its keep.

Penalties for late, missing or false EEI

The penalty section, 15 CFR 30.71, sets base amounts that are adjusted for inflation every year, so check the current figures before relying on them:

  • Failure to file: a civil penalty not to exceed $10,000. Any AES record filed more than 10 calendar days after the due date is also treated as a failure to file.
  • Late filing: up to $1,100 for each day of delinquency, but not more than $10,000 per violation.
  • False or misleading information, and other violations: up to $10,000 per violation.
  • Knowingly failing to file or filing false information: criminal fines of up to $10,000, imprisonment of up to five years, or both, per violation.

The Census Bureau also publishes guidance on AES fatal errors and a monthly AES compliance report for filers. Treat a fatal error like a CBP manifest rejection: fix it the same day. For the import side of the same trade lanes, see our guide to ACE AMS manifest filing.

Frequently asked questions

Do I need to file EEI for every ocean export?

No. EEI is generally not required when each Schedule B or HTS line from one USPPI to one consignee on one vessel is $2,500 or less, unless a license or another listed condition applies. Check 15 CFR 30.2 and 30.37 for the full rules.

When is EEI due for vessel cargo?

The EEI must be filed, and the filing citation or exemption legend given to the exporting carrier, 24 hours before the cargo is loaded on the vessel at the U.S. port. Used self-propelled vehicles must be filed at least 72 hours before export.

What is an ITN?

The Internal Transaction Number is the confirmation number AES returns when it accepts an EEI filing. It forms the proof of filing citation that goes on the bill of lading and to the carrier.

Do shipments to Puerto Rico need EEI?

Yes, shipments between the United States and Puerto Rico are covered by the Foreign Trade Regulations. For those shipments, the proof of filing or exemption legend must reach the carrier by the time the shipment arrives at the port of unlading.

Can a freight forwarder or NVOCC file AES?

Yes, as the USPPI's authorized agent. The filer must have a U.S. office, an EIN or DUNS number and AES certification, and is responsible for accurate, timely data.

Sources

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